Tax disputes under institutional instability: theory and implications

This article aims to offer the first structural analysis of tax disputes under institutional instability using a core element of the international tax regime as an example. It offers a theory grounded on Mancur Olson's seminal contribution to group dynamics, the logic of collective action. It also suggests implications of this theory that might help to address key enforcement issues faced by the international tax regime in a frequent context worldwide: institutionally unstable countries.