Doron Narotzki (Akron; Google Scholar), Tax Treaties in the Wind, 13 Penn St. J.L. & Int’l Affs. 2 (2025):

Since World War II, tax treaties have served as vital instruments for fostering cross-border investment and economic cooperation. However, the rise of economic nationalism and protectionism now threatens the stability of these agreements. This article examines what I argue is the first sign of the unraveling of the international tax treaty network, driven by a shift towards Economic Sovereignty Neutrality (ESN), a new approach that prioritizes domestic interests and economic resilience over traditional principles of capital neutrality.

The article begins by briefly exploring the historical evolution of tax treaties and their role in the global economy. It then analyzes the increasing trend of unilateral actions by countries like the United States, which have suspended treaties and raised tariffs, signaling a departure from multilateral cooperation.

The consequences of this shift in tax policy are significant: rising double taxation, increased compliance burdens, and a fragmented global tax system. The risk of a “fiscal cold war” looms as countries prioritize national interests, undermining the mutual trust that has supported international tax cooperation. To address these challenges, this article argues for a reevaluation of global alliances, urging nations to reassess who shares their economic vision and who does not. It suggests that countries should seek to build a new framework tailored to the interests of aligned allies, rather than striving for a one-size-fits-all global approach.

In this new era of fiscal disunity, the international community faces a critical choice: adapt to the changing landscape or risk the collapse of the cooperative structures that have supported global economic growth. The future of tax treaties is uncertain, and the decisions made now will shape the international tax system for decades to come.

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