Reuven S. Avi-Yonah (University of Michigan Law School) has posted A Perspective on Supra-Nationality in Tax Law on SSRN. Here is the abstract:
The international tax regime is almost a hundred years old. Its basic principles were laid out by the report of the four economists (1923) and the first (League of Nations) model convention (1927). The world has changed tremendously since then with the advent of globalization and the more recent rise of the BRICS. Thus, it is not surprising that even the OECD is raising questions about ways in which the regime can be updated to fit the needs of the 21st century. In fact, the OECD BEPS project, which is driven to a large extent by the G20 and therefore is influenced by the BRICS (who are members of the G20), has the potential of significantly altering the contours of the international tax regime.