The Motivations Behind the Framework Tax Convention
摘要
Driven by LMIC grievances, the FTC addresses inequities in taxing rights favoring HICs, challenges in taxing digital services without physical presence, and exclusion from OECD processes. The chapter critiques legacy rules like the 1920s compromise, OECD’s dominance, and BEPS outcomes, underscoring the role of the lack of inclusivity in global tax governance in the genesis of the FTC.