Multilateralism in Tax Treaty Law

MTTL
Book
Stefanie Gombotz
WU - Tax Law and Policy Series
Format/Price
9789087229351
382
EUR
125
| USD
135
(VAT excl.) Shipping fees apply. View shipping information.
Special offer
  • Order the print together with any electronic format of the same title and receive a 20% discount on each format. The discount is calculated automatically in your shopping cart.
  • Bulk discounts apply on orders of 10 or more books of the same format (this applies to each of the formats) with a maximum of 20% discount. The offer is not valid for resellers.
  • Students are entitled to a 50% discount on IBFD books and 20% discount on third party books (valid student card required).

To obtain student discounts, contact Customer Support.

Online books

Access your online books on the Tax Research Platform.
Don’t have a Tax Research Platform subscription?
Learn more

Why this book?

It is generally agreed that treaties for the avoidance of double taxation are usually international agreements between two countries, i.e., bilateral international treaties. This is also how the major international treaty models of the OECD and the UN are structured. With its roots deep in the early 1920s, “bilateralism” shapes the structure of today's international tax framework, the backbone of which is formed by around 3,000 bilateral tax treaties. In fact, there are very few historical or current examples of multilateral tax treaties. Skepticism prevailed, due to the lack of consensus on the allocation of taxing rights in situations involving many states. However, the last decade has seen a surge in multilateralism in international tax law.

It is against this background that this book explores the topic of multilateralism in tax treaty law. The book investigates one broad research question: “How has multilateralism in international tax treaty law been used in the past, what are the advantages of a multilateral approach and how could a multilateral tax treaty be used as a tool for inclusive cooperation?” It establishes a historical basis and conceptual framework to argue for increased multilateralism, which, drawing from past and present examples of multilateral tax treaties, offers many advantages over bilateral approaches that may outweigh the difficulties of a multilateral approach. The book concludes with a proposal for a “Draft Multilateral Tax Treaty” that draws on the most common model treaties, existing multilateral agreements and research findings.

To put it in the author’s words:

“The advantages of a comprehensive MTC both in aspects of concrete distributive issues as well as underlying principles are significant and should be used as a new starting point for discussions on the matter”.

This book analyses the re-emergence of multilateralism in international tax law and explores potential advantages (and disadvantages) of a multilateral approach to tax treaty law.

Multilateralism in Tax Treaty Law

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 2: The Emergence of International Tax Law

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 3: The Emergence of Multilateralism

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 4: Comprehensive Multilateral Tax Treaties

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 5: Limited Multilateral Tax Treaties and Semi-Multilateral Conventions

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 6: Arguments for a Multilateral Approach in Tax Treaty Law

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 7: Selected Issues to Be Considered in a Multilateral Approach

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Chapter 8: The Institutional Framework for a Multilateral Tax Treaty

DOI: https://doi.org/10.59403/qtqgj0
Go to Tax Research Platform

Stefanie Gombotz is an international tax law expert at the Austrian Ministry of Finance in the department for international tax law, as well as author and lecturer in national and international tax law. She completed her doctoral studies at the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business (WU), where she continues to be an external lecturer.

This book is part of the WU Institute for Austrian and International Tax Law - Tax Law and Policy Series

View other titles in the series