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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.)

Copyright of Canadian Journal of Economics is the property of Wiley-Blackwell 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.)

This article reviews international tax policy, treaties, and the nature of disputes to challenge common beliefs as to what states want in international taxation and what the interests are in tax disputes. It argues that states are implicitly part of all tax disputes on both sides of the dispute and that the taxpayer versus revenue conceptualisation is inadequate. It calls for a reconsideration of thought in these areas if progress is to be made in justice in international taxation. [ABSTRACT FROM AUTHOR]

China attaches great importance to and actively participates in the implementation of the Base Erosion and Profit Shifting Action Plan, revising bilateral tax treaties with other countries multiple times to proactively address tax dispute cases. However, since 2016, there has been a significant increase in new tax dispute cases, highlighting the urgent need for China to enhance its capacity in resolving international tax disputes and establish a comprehensive and efficient dispute resolution system. This article analyses the current operation of China's international tax dispute resolution mechanism, identifying issues such as the need for optimisation of bilateral tax treaties, inefficiencies in the operation of the mutual agreement procedure, and inadequate taxpayer participation. Additionally, the necessity and feasibility of introducing a mandatory arbitration mechanism in bilateral tax treaties are addressed, providing specific design recommendations for such mechanism. Furthermore, alternative tax dispute resolution mechanisms are also explored. [ABSTRACT FROM AUTHOR]

Copyright of Zeitschrift für Bankrecht und Bankwirtschaft 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 article reports on the decision of the U.S. Senate to approve on June 22, 2023 a resolution of advice and consent to the ratification of a tax treaty between the U.S. and Chile.

The reforms of investment treaties include the incorporation of flexibilities into standards of investment protection such as indirect expropriation to accommodate public interest regulatory autonomy. In this article, I assess the efficacy of these reforms by analysing the intersection of constitutional provisions on compulsory acquisition and regulation of property in selected African constitutions and expropriation provisions in investment treaties. I argue that indirect expropriation provisions in investment treaties are unconstitutional. I also argue that the new generation investment treaties which incorporate these exceptions do not preserve African States' authority to acquire and regulate private property. The exceptions do not resolve the incompatibility between the constitutional authority to take and regulate property without paying compensation and African States' investment treaty obligations on indirect expropriation. By providing for precatory and inefficacious exceptions to indirect expropriation while leaving intact substantive standards of investment protection, the reforms of investment treaties preserve an investment treaty law and arbitration regime that remains skewed towards investors and covered investments. [ABSTRACT FROM AUTHOR]

The article discusses profit shifting by multinational corporations (MNCs) and its impact on corporate income taxation. It explores how MNCs manipulate transfer pricing to lower tax rates and the challenges faced by governments in regulating these behaviors. The article also examines the role of the United States in the international tax system and its efforts to combat profit shifting. It discusses the impact on developing countries and the Base Erosion and Profit Shifting (BEPS) project initiated by the OECD. The article concludes by discussing the need for international tax reform and the United States' role in solving interstate profit shifting. It also highlights the challenges and limitations of implementing combined reporting for corporate income tax. The United States' stance on international tax reform and its participation in Pillar Two of the OECD's tax framework remain uncertain. [Extracted from the article]