目次

1 Introduction 2 Efforts for Multilateral International Tax Rules: 1920–1992 3 The Prospects of a Multilateral Agreement for International Taxation 4 In a Perfect World: A Normative View on Multilateral Cooperation in International Taxation 5 In a Less than Perfect World: A Realistic View on Multilateral Cooperation in International Taxation 6 A Design Strategy for a Multilateral Agreement for International Taxation 7 The Design of a Multilateral Agreement for International Taxation 8 An Evaluation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting 9 Conclusions ANNEX Draft Clauses to the Framework Convention-Protocol Design and the ‘Agreement to Scope’