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Tax treaties and the allocation of taxing rights with developing countries

Author

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  • PAOLINI, Dimitri

    () (Università di Sassari, CRENoS and DEIR; Université catholique de Louvain, CORE, B-1348 Louvain-la-Neuve, Belgium; University of Luxembourg, CREA, Luxembourg)

  • PISTONE, Pasquale

    (University of Salerno and WU Vienna)

  • pulina, GIUSEPPE

    (Università di Cagliari and Sassari, CRENoS and DEIR)

  • ZAGLER, Martin

    (WU Vienna University of Economic and Business)

Abstract

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.

Suggested Citation

  • PAOLINI, Dimitri & PISTONE, Pasquale & pulina, GIUSEPPE & ZAGLER, Martin, 2011. "Tax treaties and the allocation of taxing rights with developing countries," CORE Discussion Papers 2011042, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
    • Handle: RePEc:cor:louvco:2011042
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    File URL: http://uclouvain.be/cps/ucl/doc/core/documents/coredp2011_42web.pdf
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    References listed on IDEAS

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    1. Fleurbaey,Marc & Maniquet,François, 2011. "A Theory of Fairness and Social Welfare," Cambridge Books, Cambridge University Press, number 9780521715348.
    2. Belleflamme,Paul & Peitz,Martin, 2015. "Industrial Organization," Cambridge Books, Cambridge University Press, number 9781107687899.
    3. Chisik, Richard & Davies, Ronald B., 2004. "Asymmetric FDI and tax-treaty bargaining: theory and evidence," Journal of Public Economics, Elsevier, vol. 88(6), pages 1119-1148, June.
    4. Michael Keen & Jenny E. Ligthart, 2007. "Revenue Sharing and Information Exchange under Non‐discriminatory Taxation," Scandinavian Journal of Economics, Wiley Blackwell, vol. 109(3), pages 487-504, September.
    5. Belleflamme,Paul & Peitz,Martin, 2010. "Industrial Organization," Cambridge Books, Cambridge University Press, number 9780521681599, November.
    6. Huizinga, Harry & Nielsen, Soren Bo, 2003. "Withholding taxes or information exchange: the taxation of international interest flows," Journal of Public Economics, Elsevier, vol. 87(1), pages 39-72, January.
    7. Duranton, Gilles & Martin, Philippe & Mayer, Thierry & Mayneris, Florian, 2010. "The Economics of Clusters: Lessons from the French Experience," OUP Catalogue, Oxford University Press, number 9780199592203.
    8. Philippe Bacchetta & María Espinosa, 2000. "Exchange-of-Information Clauses in International Tax Treaties," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 7(3), pages 275-293, May.
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    Cited by:

    1. Hearson, Martin, 2018. "When do developing countries negotiate away their corporate tax base?," LSE Research Online Documents on Economics 87762, London School of Economics and Political Science, LSE Library.
    2. Julia Braun & Martin Zagler, 2018. "The true art of the tax deal: Evidence on aid flows and bilateral double tax agreements," The World Economy, Wiley Blackwell, vol. 41(6), pages 1478-1507, June.

    More about this item

    Keywords

    international corporate income taxation; tax treaties; revenue sharing; asymmetric information; uncertainty; locational decisions; principal-agent models;

    JEL classification:

    • F53 - International Economics - - International Relations, National Security, and International Political Economy - - - International Agreements and Observance; International Organizations
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
    • D82 - Microeconomics - - Information, Knowledge, and Uncertainty - - - Asymmetric and Private Information; Mechanism Design

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