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The United Nations in Global Tax Coordination fills the decade-long knowledge gap in international tax history concerning the UN Fiscal Commission, which functioned as the overarching fiscal authority during the early post-World War II economic order. With insights from political economy and international relations scholarship, this critical archival examination chronicles the tenacious activism by post-colonial developing countries to preserve source taxation rights, and by the UN Secretariat in championing the development of equitable tax rules. Such activism would ultimately lead developed countries to oust the UN as a forum for international tax norm setting. The book includes a revealing prehistory of the wartime work of the League of Nations that questions the legitimacy of the Mexico Model, the first model tax convention between developed and developing countries. This expertly researched work is essential reading for understanding the roles of politics, states, secretariats and private actors in directing global tax coordination.
The UN Fiscal Commission (1946–1954) is a void in international tax knowledge among the famed international bodies of the League of Nations’ Fiscal Committee, the OECD Fiscal Committee and the UN Group of Experts. Literature regarding it is fragmented, even perplexing, despite the Commission representing the only time in history when international tax policymaking took place under a genuinely universal forum, and when the Third World had entered the world stage. The Commission story, through an international relations lens, is central to understanding how the present international tax system came to be governed by developed countries, and is, accordingly, foundational to evaluating the fairness and inclusivity of developments on global multilateral tax cooperation.
Latin America agitates for source-country taxation rights to be recognised in the Havana Charter for an International Trade Organization and in the Bogotá Economic Agreement of the Organization of American States. The double taxation movement spreads among private sector associations. The United States pursues its tax treaty program aimed at furthering American private foreign investment.
The Fiscal Commission story and prehistory call for a revision to prevalent understandings of international tax history. The development of international tax law could well have taken a very different turn had the Commission not been eliminated. Startling parallels and lessons of the Commission story remain pertinent amid the revival of global multilateral cooperation under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting.
The outbreak of World War II saw a remnant League of Nations’ Secretariat relocating to Princeton. This ‘Princeton Mission’, supported by private American foundations and the US government, spreads the double taxation movement in the Americas, making inroads into Latin America that culminate in the negotiation of the 1943 Mexico Model.Faltering inter-American relations and the birth of the new United Nations lead the Mission to hastily organise the Fiscal Committee’s Tenth Session with little developing country representation in the attempt to legitimise its wartime work before the dissolution of the League. The result was the 1946 London Model.
Britain’s fears mount that developing countries in the Fiscal Commission will force it to cede jurisdiction to tax income from foreign investment. The Fiscal Division is chagrined by the Organisation for European Economic Co-operation’s involvement in double taxation questions by the International Chamber of Commerce and subsequently attempts to form collaborative relations with the European organisation.