The evolution of the international corporate tax regime, 1920–2008

Since the Financial Crisis of 2008, there has been unprecedented interest in, and political momentum behind, reform of the international corporate tax regime. This chapter outlines the origins and subsequent failings of the international corporate tax regime and identifies the factors that, criticism notwithstanding, have made it resistant to change since its origins in the 1920s. The chapter traces the critical periods in the development of the international tax regime as it currently stands, highlighting both victories and setbacks. The analysis presented highlights the difficulties of achieving meaningful reform in collective action problems, such as international taxation, that rely upon high-level international cooperation. The recent BEPS initiative is examined (and discussed further in Chapter 2), and presented as a reminder of the pervasiveness of the obstacles to reform identified elsewhere in this chapter, and in the rest of this book. While recent reforms have showed some promising signs, history suggests that prophecies of thoroughgoing change should be treated with caution.