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International Tax Law

LSE academics conduct research into a range of issues concerning international taxation. For example, Eduardo Baistrocchi is the principal author and editor of a treatise entitled A Global Analysis of Tax Treaty Disputes (London: Cambridge University Press, 2017). This two-volume book provides quantitative and qualitative analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Videos of individual speakers at the book's launch are available here. He is also part of the Global Tax Treaty Commentaries, IBFD, the Netherlands. The GTTC is the authoritative source for the analysis and interpretation of tax treaty practices across the globe. He is the author of the annual analysis of Article 9 of the OECD Model on transfer pricing. Baistrocchi is currently working on a monograph entitled The Making of International Taxation.

Eduardo Baistrocchi has proposed a new structure for the international tax regime, drawing on competition law and economic concepts to achieve institutional integration. The suggested framework involves all stakeholders in a bicameral legislature under UN control, ensuring due process and a balance of interests through repeated games, clustering, and logrolling. This proposal - available here -  aims to provide a means for implementing the framework convention on inclusive and effective international tax governance, as mandated by the UN General Assembly in 2023.

Dr Ian Roxan, ‘Limits to Globalisation – Some Implications for Taxation, Tax Policy, and the Developing World’, analyses the international tax system, using systems theory to explain taxation in terms of the interaction of autopoietic economic, legal and policy systems. This yields the ‘participation principle’ as an alternative to the traditional residence/source dichotomy, and has implications for taxation in developing countries and the taxation of the digital economy.