The Historical Origins of the Multilateral Tax Convention

40 Pages Posted: 5 Jan 2023 Last revised: 10 May 2023

Date Written: December 21, 2022

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.

Keywords: Multilateral Tax Convention, BEPS, Pillar One

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S. and Lempert, Eran, The Historical Origins of the Multilateral Tax Convention (December 21, 2022). U of Michigan Law & Econ Research Paper No. 23-007, U of Michigan Public Law Research Paper No. 23-007, Available at SSRN: https://ssrn.com/abstract=4308840 or http://dx.doi.org/10.2139/ssrn.4308840

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Eran Lempert

Independent ( email )

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