Tax in History: The First Tax Treaties: In Search of Origins

Abstract

The author seeks to discover sources and predecessors of the first international tax treaties that laid the foundation for the treaties on avoidance of double taxation. In doing so, he explores Russian and foreign bibliography as well as international and national legislation. The article, for the first time, contends that the S.-Petersburg commercial treaty between Russia and France of 31 December 1786 and the Convention between Russia and Saxony of 20 August 1800 may be regarded as the first tax treaties aimed at avoidance of international double direct taxation. Additionally, the prerequisite for concluding the convention was the situation of international double taxation caused by imposing the duty on the transfer of inherited estates by foreign heirs abroad. The historical method and contextual analysis were additionally employed to reconstruct the genetic development of avoidance of international double taxation. The work posits that the predecessors of the OECD and the UN Models of the twentieth century were much older and of better quality than it might be commonly assumed.