Contract theory as a guide to fairness in tax treaties

Author(s):
Ganzen, B.N. van (0000-0001-7579-6857); Broekhuijsen, D.M. (0000-0002-1986-0284); Vording, H. (0000-0001-5242-7266)
Editor(s):
Lindsay, I.K.; Mathew, B.
Published
2025
Publication type
Part of book or chapter of book

Abstract

The current international tax system is based on bilateral tax treaties that generally favour taxation by the resident state rather than by the source state. Low-income countries that have signed those treaties do not necessarily benefit from them. We investigate whether contract theory can provide guidance in discussions on a fair tax base distribution in bilateral tax treaties.

International tax lawTax treatiesFairnessContract theoryDeveloping countriesResidence stateSource stateDistributionCoercionExternalitiesSpill-overAsymmetryInformationOECD
Date issued
2025-01-29
Language
English
Publisher
London: Bloomsbury-Hart Publishing
Is part of
Fairness in international taxation (2025), p. 31-53
ISBN source
9781509968077
hdl
1887/4256186
doi
10.5040/9781509968107.ch-002