CYIL vol. 14 (2023)

CYIL 14 (2023) THE ROLE OF INTERNATIONAL ORGANIZATIONS IN ESTABLISHING THE GLOBAL… international tax cooperation, to the extent that it would be difficult to transfer, not only with regard to the materials developed, but also experts engaged in the subject matter. Many of the positive programs and institutional knowledge could be lost. A possible compromise would be transformation of at least part of the OECD into an international tax organization with a broad and open membership base. This would also potentially mean a political weakening of a position that the OECD members developed over time, a no small ask of the most economically developed states. It is also important to consider that tax policy is highly dependent on the economy and international commerce, and the concept of MNEs paying their fair share may lose momentum if prosperity and welfare are no longer priorities. The fundamentals of Pillar Two could become outdated in the future, 90 and we could lose unprecedented momentum of the willingness of the states to cooperate. This could ultimately mean losses for developing states as well. Many questions remain unanswered. If we follow the path of institutionalization, given that the OECD’s importance is increasing and its initiatives impact a growing number of states, one of the possibilities to consider is its evolution into an international tax organization. Other proposals have suggested even the IMF as a potential leader, yet warning that that legitimacy issues may persist in the absence of appropriate decision-making procedures. 91 There are also strong voices claiming that to achieve truly global, coherent, coordinated, and inclusive actions, the UN should undertake leadership in the next stage of international tax law reform. 92 Furthermore, a new international tax organization could be founded and function as a multilateral forum for governments to negotiate concrete rules and even entail a legal dispute-settlement procedure similar to that of the World Trade Organization. 93 Finally, it remains clear that even if the framework of international organizations remains the same in the near future, the debate is far from over and we may be on the verge of an institutional change. The strive to generate revenue and attract investment to improve the economies and social welfare will remain high on the agenda of governments impacted by various global events. Conclusion The international tax landscape has undergone significant changes in recent years. The traditional concept of tax sovereignty, where each country has the authority to design its own tax system, is being challenged. The shift towards a new international tax order, increased transparency, and multilateral cooperation reflects the evolving nature of taxation in a globalized economy. International organizations play a crucial role in shaping international tax policies and standards. The OECD’s two-pillar solution, endorsed by the G20, 90 DOURADO, A. P. (2022). Editorial Note: The World Split in Two and the Future of the International Tax Sys tem [pre-publication]. Intertax , 482–483. http://www.kluwerlawonline.com/api/Product/CitationPDFURL?- file=Journals\TAXI\TAXI2022055.pdf pg. 483. 91 TYCHMANSKA, A. (2021). The OECD as the Future International Tax Organization: An Inevitable Course of Events? Ibid., 614-635. http://www.kluwerlawonline.com/api/Product/CitationPDFURL?file=Journals\ TAXI\TAXI2021064.pdf, p. 614. 92 AVI-YONAH, REUVEN, S. and XU, HAIYAN and XU, HAIYAN. (2016). Evaluating BEPS: A Reconsideration of the Benefits Principle and Proposal for UN Oversight. Harv. Bus. L. Rev. , 6 , 185. p. 211. 93 RIXEN, T. (2016). Institutional Reform of Global Tax Governance. In A. Macnaughton (Ed.), Global Tax Governance: What Is Wrong and How to Fix It (Vol. 64, pp. 694). Canadian Tax Foundation (Canada). p. 325.

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