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
By: Malamis, Spyridon
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Item type | Current location | Home library | Call number | Status | Date due | Barcode |
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Artículos | IEF | IEF | OP 2141/2020/11-3 (Browse shelf) | Available | OP 2141/2020/11-3 |
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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.
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