Shu-Yi Oei (Duke; Google Scholar) presents Understanding Developing Country Tax Treaties with OECD Partners: A Multilevel Analysis at Duke today as part of its Tax Policy Seminar hosted by Lawrence Zelenak:

This paper investigates what factors predict the relative distribution of taxing rights in tax treaties signed between developing and developed countries. Existing literature posits power-based, contractualist, and institutional/contextual theories of how tax treaties allocate taxing rights between signatories. This paper examines the available evidence supporting each of these theories using multilevel regression analysis to do so. This paper ultimately finds suggestive evidence that relative power, contractually bargained-for preferences, and institutional/contextual pathways may all play some role in shaping tax treaty outcomes.

These findings hold important normative implications for evaluating not just tax treaties but also other bilateral and multilateral initiatives taking place between and among countries in global taxation more broadly.