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

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References

2005THE PRINCIPLE OF SYSTEMIC INTEGRATION AND ARTICLE 31(3)(C) OF THE VIENNA CONVENTION599 cited
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2009Investor-State Arbitration as Governance: Fair and Equitable Treatment, Proportionality and the Emerging Global Administrative Law151 cited
2013Investment Treaty Arbitration and the (New) Law of State Responsibility89 cited
2020The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!30 cited
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 Convention28 cited
2020International Protection of Investments27 cited
2020Interpreting European Law in the Light of the OECD/G20 Base Erosion and Profit Shifting Action Plan21 cited

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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 Rules10 cited

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