THE TAXPAYER’S ODYSSEY: BETWEEN DOMESTIC TAX LAW AND DOUBLE TAX TREATIES
THE TAXPAYER’S ODYSSEY: BETWEEN DOMESTIC TAX LAW AND DOUBLE TAX TREATIES

Summary/Abstract: This article examines the tensions arising when Romanian tax authorities assert jurisdiction in disregard of double tax treaties and international obligations. While developed jurisdictions focus on rethinking taxing rights in the digital economy, Romania remains entangled in basic disputes over residence and the mistaken presumption that citizenship alone sustains unlimited liability. By analyzing key cases, the study highlights how administrative practice continues to priorities sovereignty over treaty commitments, resulting in unlawful tax assessments and violations of taxpayer rights. Against this background, the analysis also turns to the phenomenon of double non-taxation, raising the question of whether such instances can, in themselves, determine or expand a state’s taxing jurisdiction.

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