Multilateral Cooperation in Tax Law

1. Introduction

For more than a century, the core structure of the international tax system has been formulated by a selected group of countries. The system was created to eliminate double taxation and to prevent tax evasion and avoidance between developed countries. Thus, the OECD has developed a set of instruments for apportioning tax bases between countries in the form of a model convention. DeterminS. 178ing worldwide income based on residence is one of the key concepts. Throughout the design of the core structure of international taxation and its growth, developing countries have been labeled as silent observers – reactive through “resilience” or “resistance” to the encroachments of powerful countries.

During the 20^th century, the economic and political environment changed. With the disappearance of colonialism and the opening of markets with the collapse of communist regimes, new players appeared on the political stage. In addition, economies became increasingly globalized, and business models changed due to the growth of the service sector and the development of electronic devises. Trade agreements were introduced to eliminate boundaries and to facilitate the global trade. This libe...