Jogarajan: The Conclusion and Termination of the 'First' Double Taxation Treaty

Sunita Jogarajan (Univ. of Melbourne - Law) has posted The Conclusion and Termination of the 'First' Double Taxation Treaty (British Tax Review, forthcoming). Here's the abstract:

In 1872, Great Britain and Switzerland (Canton of Vaud) concluded an agreement for the prevention of double taxation in respect of death duties. The Agreement holds a significant place in history as it is the first officially recorded agreement between countries which solely and directly addresses the issue of double taxation, albeit in a limited manner. Despite its prominence as the “first” double taxation agreement, little has been written about the Agreement. Given the current proliferation of bilateral treaties regarding double taxation, it is perhaps beneficial to consider why and how the “first” such treaty was concluded. This article traces the history of the Agreement to understand why these two particular parties were motivated to conclude such an agreement and how the final form of the Agreement was reached. The article then turns to the termination of the Agreement to understand the reasons why the Agreement was terminated and the considerations undertaken in that process. This examination of the life cycle of the Agreement presents an interesting snapshot of many of the issues which have arisen and continue to arise in the negotiation and conclusion of double taxation treaties.