Global Tax Politics, North, South, international taxation
The publication of Martin Hearson’s book, Imposing Standards: The North-South Dimension to Global Tax Politics, coincided with heated international discussions of the most substantial policy proposals in the field of international taxation in the last century.1 Hearson’s work provides insights on how the developed countries exerted control over the negotiations of the double taxation agreement (DTA) regime, which is the basis of the current international taxation framework. It explains how the negotiations resulted in a framework that works well for the developed countries, but does not substantially address the tax revenue needs of the developing countries. The publication of the book is timely because some of the same tensions that underlie those DTA negotiations also underlie the current policy proposals on the tax consequences of the digitalized economy.
Hearson’s book examines the unequal bargaining power between the developed countries (also described as capital exporting countries in this
review) and the developing countries (also described as capital importing countries in this review) in the negotiation of tax treaties.2 Hearson details how the developed countries were able to infuse their standards into tax treaties without considering their compatibility with the economies of their treaty partners, and the negative impacts those standards might have on tax revenue needs of those treaty partners. The analysis is supported by empirical data from selected countries, interviews with key revenue officers, analysis of official records, and review of tax treaties of the United Kingdom, Zambia, Cambodia, Vietnam, and other countries. The book can be broadly divided into two parts. The first part provides a rich literature on a variety of issues affecting the interests of the developing countries in the negotiation of tax treaties while the second part puts those issues in the context of the empirical data of the comparable countries.
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Opeyemi Bello, "Are the Imposed Principles Standard? A Review of Imposing Standards: The North-South Dimension to Global Tax Politics by Martin Hearson" (2023) 46:1 Dal LJ 483.