The International Tax Regime in the Twenty-First Century: The Emergence of a Third Stage

• Autores: João Marcus de Melo Rigoni
• Localización: Intertax, ISSN 0165-2826, Vol. 45, Nº. 3, 2017, págs. 205-218
• Idioma: inglés
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• Resumen

  • This article presents a new approach to the study of the international tax regime (ITR) since its creation in the 1920s by the League of Nations.

    It benefits from two leading frameworks which provide the normative structure explaining the existence and dynamic of the ITR. This article assumes that the ITR is built on three building blocks: the single tax principle, the benefit principle and market leaders for quasi-legal rules.

    Following the development of each one of them during the last century, a new three-stage division of the history of the ITR is proposed here; two different stages are already completed. The Base Erosion and Profit Shifting project, regardless of the outcome, has just inaugurated the third one.