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Does the conclusion of a DTA serve the fiscal interests of high tax jurisdictions?

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Published on 01 Apr 20 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This article examines whether the fiscal interests of high tax jurisdictions, considered in the context of both developed and developing nations, are promoted or, in the alternative, preserved when concluding double tax agreements (DTAs) with low tax jurisdictions or those with territorial tax bases. To resolve this position, the article considers the main tax fiscal and political drivers which motivate a jurisdiction to conclude a DTA. These drivers will then be contrasted with the specific tax policy objectives of high tax jurisdictions which forms the contextual framework for analysis. The central thesis of this article is that, regardless of the constitution of the high tax jurisdiction, the conclusion of a DTA with low tax or territorial counterparts broadly achieves an outcome contrary to the fiscal interests and objectives of the high tax jurisdiction, and often at the significant expense of the tax base.

Author profile

Donovan Castelyn CTA
Donovan Castelyn, CTA, is the Co-Founder of the Curtin Tax Clinic, Australia’s first pro-bono tax clinic and the impetus for the National Tax Clinic Program and currently a Senior Industry Fellow - Taxation at the University of Tasmania (UTAs) and Director of the UTAs Tax Clinic. Donovan holds higher degrees and qualifications in both law and commerce, is admitted as a Lawyer of the Supreme Court of Western Australia and is recognised as a Chartered Tax Adviser and Chartered Accountant. Donovan is also pursuing his PhD in the field of financial and tax literacy and has previously been recognised as one of Australia’s leading young tax professionals received the Tax Adviser of the Year Award for Emerging Tax Stars in 2020. - Current at 12 July 2023
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