An International Tax Regime in CrystallizationUF Law Faculty Publications
AbstractThe grand illusion of a single, worldwide, tax system that will eliminate all international inefficiencies, and assist all the nations of the world to maximize their relative advantages, is, as commonly accepted, utopian. The tax, academic and professional, writing in the field of international taxation, and cross-border interaction, between tax systems and jurisdictions has grown, exponentially, in the last decade, but no significant work has been done to prove, or disprove, the naivety of this hypothesis. Some scholars and tax executives, in certain international organizations, have discussed ideas along this line, but no single organization has, seriously, attempted to promote global tax harmonization. Additionally, no national government has provided support to enable research of this idea. In this paper I advocate the benefits of a true global approach. I examine the possibility of worldwide adoption of a single set of international tax rules. Unlike prior literature I seek to avoid an "all-or-nothing" perspective for the analysis of a possible World Tax Regime, and, prefer to explore each component of it as it is at present in light of a unification proposal. Eventually, I advocate a gradual and partial rule-harmonization effort led, preferably, by the OECD. My intention is not to present a specific proposal, but present a framework for thinking about it and, possibly, negotiating it. The basic theme is that any one (or more) of the sets of rules of international taxation could be adjusted at any given, practical time, and then, gradually, as possible, the rest of the rules may be brought into harmony. The structure of the international tax rules allows for such flexibility and gradualness without adverse implications.
Citation InformationYariv Brauner, An International Tax Regime in Crystallization, 56 Tax L. Rev. 259 (2003), available at http://scholarship.law.ufl.edu/facultypub/9