The recent adoption by the UN General Assembly of the resolution of 22 December 2023 calling for the development of a framework convention (A/ RES/78/230 2023) to strengthen international tax cooperation aligns with the liberal promise of legitimate, fair, and stable international tax governance institutions. In this article, the authors argue that there is reason to doubt that promise. They consider the more sober neorealist view of international relations according to which the world is characterized by zero-sum competition between the major powers whose most important aim is to secure their own survival. This perspective has remained underexplored in the international tax literature and suggests that adopting the UN General Assembly Resolution is unlikely to promote the stability and fairness of international tax cooperation. It rather serves as a warning that geopolitical tensions have infiltrated international tax matters and threaten the stability of the international tax regime as it is currently known.
Intertax