Non-discrimination in Tax Treaty Law and World Trade Law: The Impact of Formal, Substantive, and Subjective Approaches

Non-discrimination in Tax Treaty Law and World Trade Law is the first comprehensive review of non-discrimination rules in World Trade Organization (WTO) and tax law, combining critical commentary on case law with proposals for an innovative new concept for solving cases of discrimination in tax treaty law. Non-discrimination is a central obligation under both tax treaty law and trade law, but its application raises complex challenges in the Base Erosion and Profit Shifting era. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work explains the policy issues and how non-discrimination analysis works.