Stamp, Seligman and the Drafting of the 1923 Experts’ Report on Double Taxation

Abstract

In 1923, the League of Nations published the Report by the Experts on Double Taxation (“the Report”). The Report discusses the economic consequences of international double taxation, the general principles which govern international competence in taxation and the application of those principles for the avoidance of double taxation. While there is some question as to the extent of the impact of the Report on the development of bilateral tax treaties practically, there can be little doubt that the Report was a seminal work in the intellectual debate. Utilizing original archival research, this paper considers how the Report came to be produced in its final form. The chronological narrative highlights the views of the individual authors, the considerations that influenced each one and the eventual compromises reflected in the Report. The correspondence may be obtained via the IBFD library http://www.ibfd.org/Library. The paper finds that the authors were unable to ignore practical issues and the likely inertness of economic forces in formulating their final conclusions, despite their theoretical leanings.

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