International Investment Agreements and the International Tax System: The Potential of Complementarity and Harmonious Interpretation

Robert J. Danon · Sebastian Wuschka

12 citations0/0 files storedBulletin for international taxation

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Taxation and Legal Issues International Arbitration and Investment Law Corporate Taxation and Avoidance

Abstract

In this contribution to the 75th anniversary issue of the Bulletin for International Taxation, Professor Robert Danon and Sebastian Wuschka discuss the interplay between international investment agreements and corporate taxation measures. The authors shed light on the potential of complementarity and harmonious interpretation between the investment treaty regime and the international tax system.

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References

2005THE PRINCIPLE OF SYSTEMIC INTEGRATION AND ARTICLE 31(3)(C) OF THE VIENNA CONVENTION 2009The International Law of Investment Claims 2004The Hybrid Foundations of Investment Treaty Arbitration 1986Towards a Greater Depoliticization of Investment Disputes: The Roles of ICSID and MIGA 2009Investor-State Arbitration as Governance: Fair and Equitable Treatment, Proportionality and the Emerging Global Administrative Law 2013Investment Treaty Arbitration and the (New) Law of State Responsibility 2020The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!2012Using EU Law To Interpret Undefined Tax Treaty Terms: Article 31(3)(c) of the Vienna Convention on the Law of Treaties and Article 3(2) of the OECD Model Convention

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2022The OECD/G20 Global Minimum Tax and Dispute Resolution: A Workable Solution Based on Article 25(3) of the OECD Model, the Principle of Reciprocity and the GloBE Model Rules

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