Indonesian Tax Justice Review
Vol. 2 No. 3 (2025): August, 2025

Tax Treaties and Source-Based Taxation in Southeast Asia: A Justice-Oriented Comparison

Noor Aryani Puspa (Universiti Malaysia Terengganu)
Aruna Bhakt Samudra (IPB University)



Article Info

Publish Date
31 Jul 2025

Abstract

Tax treaties play a critical role in allocating taxing rights between countries, often constraining source-based taxation in developing economies. This paper compares tax treaty networks and withholding tax provisions in Indonesia, Thailand, and Malaysia. Using doctrinal treaty analysis, the study evaluates the distributive consequences of treaty design. The findings indicate that extensive treaty concessions significantly reduce source-country revenues. The paper argues that treaty policy choices have long-term implications for tax justice. The global contribution of this study lies in highlighting how treaty practices in ASEAN reflect broader structural inequities in international tax law. The study contributes to calls for treaty reform to better protect developing country interests.

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Journal Info

Abbrev

tax

Publisher

Subject

Description

Indonesian Tax Justice Review (e-ISSN: 3164-7553) is published by COLLEGIUM JUSTICIA INDONESIA, issued four times a year in February, May, August, and November, and was first published in 2024. It is a double anonymous peer-reviewed academic journal focusing on the relationship between tax law, ...