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Copyright of Zeitschrift fur Wirtschaftspolitik is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

The 1947 United Kingdom-New Zealand double taxation agreement was New Zealand's first comprehensive double tax treaty and one of the United Kingdom's earliest tax treaties. Initiated by the United Kingdom only two years after the landmark negotiation of the 1945 United States-United Kingdom treaty, the agreement largely reflected its contemporary tax policy toward its Dominions. It was concluded before the OECD produced the first version of its influential model treaty in 1963, and its drafting was influenced by other United Kingdom treaties. Although rudimentary compared to modern tax treaties, the agreement contained most of the provisions found in standard double tax agreements, albeit in an embryonic form. This article examines the provisions of the 1947 treaty and compares them to the articles of the OECD Model Convention, the basis for almost all modern double tax treaties. The 1947 treaty was a significant moment in the development of New Zealand's network of double tax treaties and is also a reminder of New Zealand's close ties to the United Kingdom at the time. [ABSTRACT FROM AUTHOR]

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Developing countries have more than 1300 investment treaties with developed countries. Investment treaties are often alleged to constrain developing countries' climate policies. This paper examines four treaty reforms that are often suggested as remedies to such regulatory chill. It considers an investment treaty that protects a stranded developed country investment in a developing country. The reforms are compared with regard to whether they can induce the developing country to regulate the investment, and their political attractiveness. The reforms are shown to have features that seem to have gone unnoticed in the debate. Exclusion of investor-state dispute settlement (ISDS) may be ineffective due to a hold-up problem, and if effective requires unlawful regulation by the host country. A shortening of a sunset period applicable to unilateral withdrawal can postpone regulation. A reduction in the amount of stipulated compensation can induce the developing country to phase out the stranded investment, but will require a compensation payment from the developing country to the developed country investor. The reform with best potential to address stranded investment problems appears to be an increase in a carve-out from the compensation requirement for measures with sufficiently positive climate effect. [ABSTRACT FROM AUTHOR]

In this Article, we use the Association of Southeast Asian Nations (ASEAN) as a case study to question whether the proposed establishment of multilateral institutions (namely, a Multilateral Investment Court or a standing appellate mechanism), as part of investor-State dispute settlement (ISDS) reform efforts, will adequately address the concerns and priorities of individual States. The varied content and overlapping nature of the investment treaty portfolios of ASEAN Member States, as well as their varied experiences with ISDS to date, mean that key concerns and priorities that ASEAN Member States have expressed about the current regime of ISDS (consistency and coherence, representation, and cost-efficiency) may not be adequately addressed unless the proposed multilateral institutions are flexibly structured to allow for regional adaptation. Given this assessment, we suggest two ways for such regional concerns to be reflected in the United Nations Commission on International Trade Law's (UNCITRAL) multilateral reform proposals, namely: (i) for UNCITRAL to establish a mechanism to allow for treaty-specific chambers within a Multilateral Investment Court or a standing appellate mechanism; and (ii) for ASEAN Member States and their Free Trade Agreement (FTA) partners to capitalise on the opportunity afforded by the Regional Comprehensive Economic Partnership (RCEP) to move towards a consolidation of investment treaty rules and dispute settlement among ASEAN Member States, as well as between ASEAN Member States and the ASEAN FTA partners. [ABSTRACT FROM AUTHOR]

Copyright of Muhasebe ve Vergi Uygulamalari Dergisi (MUVU) / Journal of Accounting & Taxation Studies (JATS) is the property of Ankara Serbest Muhasebeci Mali Musavirler Odasi and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)