THE INTERNATIONAL TAX FRAMEWORK AS AN INSTRUMENT OF FOREIGN DOMINATION

Abstract

The aim of this paper is to investigate if the international tax framework plays an integral role on the fourth pattern of foreign domination as identified by Florestan Fernandes, also known as “Total Imperialism” or “Corporate/Monopolistic Capitalism”. In order to do that, this article examines some of the basic assumptions of this sociologic model, taking the writings of “Contingent Capitalism and Social Classes in Latin America”, and identifying a tax gap. In the following section, the origin of the principles and rules that form the international tax framework is analyzed, pointing out the motivations and findings of the work conducted by the League of Nations in the 1920s. In the final section, the article proposes its main thesis that the OECD Model Tax Treaty is fundamental for the “Corporate Capitalism” acting as an instrument of foreign domination, ensuring that the developed capitalist nations could accrue capital derived from earnings removed from the outskirts countries.