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: Suggested Citation