This chapter offers the first global taxonomy of treaty dispute patterns emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the taxonomy are as follows. The time dimension covers the era which ran from 1923 — when four economists...

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and...

The way in which the countries studied here solve tax treaty disputes is normally related to exogenous elements. Local endowment of natural resources is a neat example. This can be seen as a continuum. On one end, countries with large endowments of natural resources, such as Argentina, Brazil...

This chapter offers the first global quantitative analysis of tax treaty disputes emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the analysis are as follows. The time dimension covers the era that ran from 1923 — when four...

The allocation norm regarding the profits of associated enterprises, now encapsulated in Article 9 of the OECD and UN Model Conventions, is engaged in a creeping, spiral evolution since the beginning of the 20th century: from standards to rules, and then back to standards. The spiral trajectory...

The global economy's centre of gravity is shifting. Emerging and developing countries have been contributing over 50% of the global GDP since the onset of the 21st century, which is unprecedented since the Industrial Revolution. This article offers the first analysis of the creeping convergence...

A Theory of International Taxation combines qualitative and quantitative analyses to shed light on the shaping of the international tax regime (ITR) over the last century. It offers a theory of the ITR as the product of the strategic interaction between three small groups: international...

The global economy’s center of gravity is shifting. For the first time since the 19th century, emerging and developing countries have been contributing over 50% of the global GDP since the onset of the 21st century. If soft power mirrors but lags behind economic power, then the source for...

Global tax hubs are the black boxes of the international tax regime (ITR). The driving forces of their strategic interaction with other building blocks of the ITR remain underexplored. This paper offers the first theory of global tax hubs as an intermediation market using antitrust law as...

A Theory of International Taxation combines qualitative and quantitative analyses to shed light on the shaping of the international tax regime (ITR) over the last century. It offers a theory of the ITR as the product of the strategic interaction between three small groups with market power:...