The Historical Origins of the Multilateral Tax Convention

Document Type

Article

Publication Date

2023

Abstract

This paper will survey the efforts to create a multilateral tax convention (MTC) from the beginnings of the international tax regime to the present day. The paper’s main contribution is to provide a historical analysis of the (failed) efforts to create a MTC from the beginnings of the ITR until the League of Nations (as contained in Part 1 to this paper). Part 2 of the paper serves to provide a brief modern context to the historical analysis from Part 1, covering why the multilateral instrument (MLI) that was included in BEPS 1.0 is not a true MTC, and secondly points to the BEPS 2.0 effort to develop a true MTC. Part 3 will conclude by discussing under what conditions can a true MTC emerge and what it might look like.

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