Double Taxation and the League of Nations in the 1920s

Abstract

This thesis considers the development of the first model tax treaties by the League of Nations in the 1920s based on archival research in the League's archives in Geneva, and also in other archives in the UK and the US. The thesis shows that once the first resolutions were agreed by a small committee in 1925, the enlarged committee constituted for meetings in 1927 and 1928 was unwilling to reopen the earlier agreement reached. As a result some common assertions in the literature are found to be incorrect: the International Chamber of Commerce and the US delegate TS Adams had little impact on the development of the League's models, and the UK and US did not operate in concert to push a developed country bias in the development of the model treaties. More generally the thesis finds that common assertions about the history of tax treaties in the League of Nations in the current debates over taxation of multinationals are incorrect.