Shu-Yi Oei (Duke; Google Scholar) presents Understanding Growing Nation Tax Treaties with OECD Companions: A Multilevel Evaluation at Duke at the moment as a part of its Tax Coverage Seminar hosted by Lawrence Zelenak:

This paper investigates what elements predict the relative distribution of taxing rights in tax treaties signed between growing and developed nations. Current literature posits power-based, contractualist, and institutional/contextual theories of how tax treaties allocate taxing rights between signatories. This paper examines the out there proof supporting every of those theories utilizing multilevel regression evaluation to take action. This paper in the end finds suggestive proof that relative energy, contractually bargained-for preferences, and institutional/contextual pathways might all play some position in shaping tax treaty outcomes.