The international tax landscape has changed radically in the last decades. Evidence of this development can be shown in the change of strategy pursued by the OECD and the EU in order to tackle tax base erosion and profit shifting. The unilateral or bilateral solutions traditionally adopted by States have given way to multilateral solutions based on consensus and cohesion reached at global level among States.
The multilateral phenomenon is strengthened as the most efficient solution to avoid double non-taxation in the short, medium and long term. For reaching its final consolidation, a leading role needs to be played by the States.
