As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope.

This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the  available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts s.

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The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.

• Chapter One: Defining the research questions
• Chapter Two: Quantitative Analysis - The Empirical Evidence
• Chapter Three: Domestic Institutional Design and the Intent of Tax Treaties
• Chapter Four: Beyond International Anarchy
• Chapter Five: Current Procedures and the Need for Change
• Chapter Six: Arbitration the - Ugly Duckling
• Chapter Seven: Designing the New Institution: Objectives, Suggested Procedures, and Analysis

Before arriving at Harvard University, Dr Zvi D. Altman was an international tax advisor in Israel. He has published numerous articles in professional journals and newspapers, and has lectured extensively on international and domestic tax issues.During his stay at Harvard, Mr Altman held several teaching and fellowship positions. He is currently with the tax group of Sullivan & Cromwell LLP in New York.

The mission of the International Bureau of Fiscal Documentation is: “[T]o maintain a knowledge centre providing information about and explanations of international taxation and promoting the study of taxation in general” (Art. 2 of the articles of association). True to this mission, and aware that access to doctoral theses is often limited, IBFD has taken the initiative to make available to a wider public a series of books based on doctoral research, meeting the highest academic standards.

Only contributions that enhance the international academic tax debate are accepted. In order to ensure high quality, every thesis published in this series has been reviewed by academic members of the Board of Trustees, senior IBFD research staff or prominent tax academics worldwide. The series aims to cover all aspects of comparative and international taxation, not only in respect of income tax, but also in respect of VAT and of inheritance, estate and gift taxes.