The Resource The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system

The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system

Label
The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system
Title
The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system
Creator
Subject
Language
eng
Summary
The article analyses the political objectives of states within the International Tax Dispute Resolution (ITDR) system and through a comparative analysis opposes it to the international investment and trade regime and disputes. In the second part of this article, the author argues that a greater need for enhanced tax certainty in the post-BEPS era and a potential trajectory of the traditionally bilateral international tax system towards more multilateral structures (illustrated by a possible introduction of the new Unified Approach) require the reconsideration of a careful implementation in the ITDR system of particular elements of the existing dispute settlement systems in the international investment and trade regime
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 48 (2020), no. 11 ; p. 966-983
http://library.link/vocab/creatorName
Malamis, S.E
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • WTO
  • investment treaty
  • trade agreement
  • MAP
  • arbitration
  • dispute resolution
  • tax treaty
  • BEPS Project (OECD)
  • Unified Approach (OECD)
  • Pillar 1 (OECD)
  • Pillar 2 (OECD)
  • tax certainty
Label
The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system
Instantiates
Publication
Label
The future of OECD tax arbitration : the relevance of investment treaty and WTO dispute settlement practice in promoting a gradual evolution of the international tax dispute resolution system
Publication

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