Resumen de Tax treaties with developing countries and the allocation of taxing rights

Dimitri Paolini, Pasquale Pistone, Giuseppe Pulina, Martin Zagler

• Worldwide income taxation in the country of residence is a legal dogma of international taxation. We question this dogma from the perspective of relations between developed and developing countries from legal and economic perspectives, and make a modern and fair proposal for tax treaties. We show under which conditions a developing and a developed country will voluntarilysign a tax treaty where the developing country is more inclined to share the information with the developed countryand whether they should share revenues. Moreover, we demonstrate how the conclusion of a tax treaty can assist in the implementation of a tax audit systemin the developing country.