Rozwój umów dotyczących podwójnego opodatkowania w międzynarodowych stosunkach podatkowych

The paper is a historical outline of contracts concerning avoidance of double taxation (bilateral and multilateral) and how international organisation are engaged in this problem. The author presents some bilateral contracts from the interwar period, both trade contracts and those which strictly eliminate the phenomenon of double taxation. A detailed analysis refers to some approved legal solutions. They prevent or eliminate double taxation with regard to income and inheritance taxes. Historically speaking, the problem of avoiding double taxation was supplemented by the presentation of outcome, and at the same time essential contribution of international organisation into the solution of the problem of double taxation. Such international organisation as the League of the Nations, the United Nations, and OECD played a particular role here. The considerations concerning some developmental tendencies have allowed us to assess the binding legal constructions and show how bilateral means have evolved, what contracts of avoiding double taxation we had and have now. A retrospective approach to the problems in question is essential when we want to analyse the currently binding bilateral contracts with regards to this issue, for they are based on the patterns of some legal constructs that have been worked out. The problems outlined here are especially significant in the period of a dynamic development of international relations, including the level of taxation.