International - Tax Base Defence: History and Reality
- C.H. Lowell; B. Wells
- International Transfer Pricing Journal, 2013 (Volume 20), No 2
- 25 February 2013
The authors consider whether existing model treaties provide (i) protection for the tax base of the respective countries and (ii) guidance to MNEs for framing their effective tax rate strategies. The historical origin of the OECD and UN Model Conventions is presented, along with suggestions for a way forward under present circumstances.