Avi-Yonah in this paper interrogates the basic question as to why International Tax is bilateral compared to other areas of international law. Avi-Yonah notes that international tax law has traditionally been built upon bilateral treaties and unilateral actions, and by contrast, International trade law has traditionally been built upon multilateral treaties, with international investment law, although bilateral, containing Most Favored Nation (MFN) clauses that render it effectively multilateral. Avi-yonah’s paper explores the reasons and asks whether they are still valid.
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About the author
Reuven S. Avi-Yonah