Tax treaties with Developing Countries and the Allocation of Taxing Rights

Dimitri Paolini, Pasquale Pistone, Giuseppe Pulina, Martin Zagler

Publication: Scientific journalJournal articlepeer-review


Worldwide income taxation in the country of residence is a legal dogma of international taxation. We question this dogma from the perspective of relations between developed and developing countries from legal and economic perspectives, and make a modern and fair proposal for tax treaties. We show under which conditions a developing and a developed country will voluntarily sign a tax treaty where the developing country is more inclined to share the information with the developed country and whether they should share revenues. Moreover, we demonstrate how the conclusion of a tax treaty can assist in the implementation of a tax audit system in the developing country.
Original languageEnglish
Pages (from-to)383 - 404
JournalEuropean Journal of Law and Economics
Issue number3
Publication statusPublished - 2016

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