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

Resource Information

The work 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 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

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

Creator

• Malamis, S.E

Subject

• MAP
• OECD
• Pillar 1 (OECD)
• Pillar 2 (OECD)
• Unified Approach (OECD)
• WTO
• BEPS Project (OECD)
• dispute resolution
• investment treaty
• tax certainty
• tax treaty
• trade agreement
• arbitration

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

Geographic coverage

International

Language note

English