国际税收协定属于国际经济法范畴,是以国家为主体,以国家间税收管辖权益关系为调整对象的法律规范,是经缔约国双方或多方按照国际法有关主权和平等的原则,通过谈判,以书面形式签订的协议或条约。国际税收协定是随着国际政治经济形势的演变所导致的增进税收协调合作的实际需要而发展起来的。最早的税收协定,可以追溯到1843年法国与比利时和1845年比利时与荷兰签订的税务合作和税收情报交换协定,以及1899年奥匈帝国与德国缔结的税收条约等。但是,其大量发展却是在第二次世界大战以后。这一方面是由于战前各国垄断资本从经济上瓜分 International tax treaties belong to the category of international economic law. They are the legal norms regulated by the state as the main body and the tax-rights relationship between nations. They are negotiated by both or more parties to the treaty in accordance with the principles of sovereignty and equality under international law. Signed agreement or treaty. International tax treaties are developed with the actual needs of improving tax coordination and cooperation as the international political and economic situation evolves. The earliest tax treaties can be traced back to the agreements on tax cooperation and tax information exchange between France and Belgium and Belgium in 1845 and the Netherlands in 1843, and tax treaties concluded between Austria and Hungary in 1899 and Germany. However, its massive development took place after World War II. This is partly due to the economic division of monopoly capital by nations prior to the war