Tax Treaties: Historical

• League of Nations (1928)
• Mexico Draft (1943)
• London Draft (1946)
• OECD Draft (1963)
• OECD Model (1977)
• UN Model (1980)

This collection of treaties is intended to show the development of tax treaties over the years.

In the League of Nations treaty (1928), the source country retained substantial rights to tax the income of residents of a treaty partner. The basic principle was that all income should be taxed once and only once. That principle cannot be implemented, in a world in which some countries use a territorial tax system unless the source country retains substantial rights to tax. The Mexico draft extended the rights of the source country to tax.

In the London draft, the rights of the source country to tax were curtailed substantially. Those rights were curtailed even more in the OECD draft of 1963 and in its first model convention, published in 1977.

In response to the OECD curtailment of source jurisdiction, the United Nations, as successor to the League of Nations, prepared a model convention in 1980. That model did expand source jurisdiction some, but it allowed far greater encroachment on source jurisdiction than the League's 1928 draft or the Mexico draft of 1943.