From the introduction:
Governments rely heavily on taxes to fund their operations. If the business transactions subject to tax are entirely domestic, a country wields considerable power to implement a tax system and collect the designated taxes. But if the transactions cross national borders, who taxes them? Whose rules apply? And, perhaps most important, what happens when countries disagree? Who "prevails" and why? These are serious, critical, and relevant questions for which there are few answers. The dominant focus of international tax literature has been an analysis of substantive tax law and its implications. Receiving much less attention is how countries have come to agree on particular tax rules and practices-the international relations of international tax.
Diane M. Ring. "International Tax Relations: Theory and Implications." Tax Law Review 60, (2007): 83-154.