Abstract
A solution is necessary to the potential problem of how to treat income tax issues that can affect trade matters regulated by the WTO. Should tax issues be addressed within the WTO as part of a new agreement? Should tax issues be singled out, expressly excluded from the WTO and left to be dealt with by the OECD or other international organizations? Or should some tax issues be included and others excluded? If so, how should the determination be made, and why? Should a dispute including both tax and trade issues be resolved under the WTO dispute system, or should such be resolved diplomatically outside the WTO? No single answer exists to any of these questions, and most scholars who have dealt with these issues have differed in their opinions; in fact, some have changed their opinions over time.