The 21st Century Multilateralism in International Taxation: The Emperor’s New Clothes?

This contribution attempts to shed light on the concept of multilateralism in international taxation. Rather than a shift from bilateralism to multilateralism, the author will argue that unilateralism, bilateralism and multilateralism continuously overlap in this field. This flawed narrative in relation to the shift may allow us to think that the BEPS Project and global transparency in exchanges of information are leading to a global tax law: global decision-making and better solutions for developed as well as for non-developed countries. Instead, the author will claim that the current multilateral frameworks are premised on the benefits principle, which reinforces the division between developed and non-developed countries. The increase in global inequalities and poverty have led the author to propose a different multilateral framework on international taxation based on the idea of distributive justice. In other words, a multilateral framework that moves away from the dichotomy of source v. residence taxation to embrace solidarity is both desirable and feasible. Finally, the article will acknowledge the fact that regional integration processes, defined as “thick multilateralism”, already encapsulate harmonization mechanisms and an idea of justice among the EU Member States that strengthen the struggle against the existing inequalities and asymmetries.