International tax disputes, their causes and means of resolving them

Hussein Mohamed, Alaa; Ahmed Mahmoud, Hesham; Ahmed Aly, Ayman; Abd El Zaher Aly, Ragab

doi:10.21608/ijarlg.2022.413740

International tax disputes, their causes and means of resolving them

Document Type : Original Article

Authors

¹ Department of Private International Law - Faculty of Law - Beni Suef University

² Department of Public Finance - Faculty of Law - Aswan University

³ Department of Labor Law - Faculty of Law - Beni Suef University

10.21608/ijarlg.2022.413740

Abstract

Abstract:
The summary of this research revolves around, If taxation is based on the principle of territorial sovereignty; That is: every country has the right to impose taxes on income and activities within the scope of territorial jurisdiction; However, with the dominance of globalization, the spread of internationally active companies, and the entry into force of the World Trade Organization Agreement, the effectiveness of this principle has faded, which constitutes an element of pressure on the resources of developing countries that depend on taxes as a necessary source of income.
It was necessary to have an international tax law that works to achieve harmony between tax legislation in different countries. The efforts of countries have culminated in the development of collective model treaties that are used as a guide to determine the tax sovereignty of different countries over incomes and capital.
Moreover, many countries have concluded bilateral and collective agreements; From all of these international tax agreements, the basic principles of international tax law are formed. These basic principles are what we hope will illuminate the way for the legislator of each country in the tax field with the aim of avoiding conflict of laws in the tax field. And its negative effects on the economies of countries around the world.

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