Tax treaties and the Allocation of Taxing Rights with Developing Countries, CORE-DP 2011/42

Global income taxation in the country of residence is a legal dogma of international taxation.
We question this dogma from the perspective of relations with developing countries from a
legal and economic perspective, and make a modern and fair proposal for tax treaties. We will
show under which conditions a developing and a developed country will voluntarily sign a tax
treaty where information is exchanged truthfully and whether they should share revenues.
Moreover, we will demonstrate how the conclusion of a tax treaty can assist in the
implementation of a tax audit system.