International Tax Law as an Event-Generating Infrastructure: A Fiscal Geometry Reading of Sovereignty, Treaties, and Enforcement

This paper offers a non-doctrinal, visibility-first reading of international tax law as an event-generating infrastructure. Rather than interpreting treaty provisions for doctrinal correctness or proposing policy reform, the paper treats international tax rules as an institutional routing system: a structured set of interfaces (treaty allocation rules, residence tests, source rules, withholding mechanisms, reporting obligations, and enforcement channels) that generate observable events and move agents across fiscal states. Using Fiscal Geometry as a representational framework, the paper renders cross-border tax coordination as a sequence of entry nodes, evidentiary triggers, and routing consequences. Sovereignty is examined not as an abstract principle but as a design variable expressed through interface choices—what counts as admissible evidence, which documents activate obligations, how conflicts are resolved, and where enforcement capacity is placed. Treaties are treated as routing protocols that reclassify capital and obligations across jurisdictions, while enforcement is treated as the closure mechanism that determines whether routing decisions remain stable over time. The contribution is methodological. The paper provides a neutral representational grammar for observing how international tax law produces structured fiscal movement without relying on narrative explanation or doctrinal debate. It is intended to support comparative analysis and future empirical or computational extensions while remaining non-prescriptive and not offering compliance or legal advice.