Malamis, Spyridon
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 / Spyridon E. Malamis .-- , 2020
Resumen.
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.
INVERSIONES
FISCALIDAD INTERNACIONAL
RESOLUCIONES EXTRAJUDICIALES DE CONFLICTOS
ARBITRAJE
Intertax 0165-2826v. 48, issue 11, November 2020, p. 966-983
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 / Spyridon E. Malamis .-- , 2020
Resumen.
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.
INVERSIONES
FISCALIDAD INTERNACIONAL
RESOLUCIONES EXTRAJUDICIALES DE CONFLICTOS
ARBITRAJE
Intertax 0165-2826v. 48, issue 11, November 2020, p. 966-983