How to Prepare

1)  Read the article in advance: "International Investment Agreements and the International Tax System: The Potential of Complementarity and Harmonious Interpretation" 

2)   Think about one or two sentences in the article that intrigued you.

3)   Reflect on these guiding questions:

·      The article claims that the international tax system and investment treaty regime offer considerable potential for complementarity. The fair and equitable treatment (“FET”) standard ensures a harmonious interpretation between the investment treaty protection regime and international tax standards.

Does the introduction of the global minimum tax under Pillar 2 reinforce the complementarity between the international tax system and the investment treaty regime, particularly concerning the fair and equitable treatment (FET) standard, or does it pose challenges to the interpretation and application of FET in investment treaties?

·  The article highlights the key differences in dispute resolution mechanisms between the investment treaty regime and the international tax system. The authors suggest that the independent arbitration tribunal presents distinct advantages compared to mutual agreement procedure and even tax treaty arbitration. Furthermore, the article concludes by addressing the potential for the international tax system to develop an effective dispute-resolution mechanism inspired by the investment treaty framework.

Considering the new developments at the UN with negotiations of a UN Tax Framework Convention and the choice of the second protocol, “Prevention and resolution of tax disputes,” how can dispute resolution in tax-related issues be addressed through UN processes without creating fragmentation in the system?

Meeting Format

1)    Welcome & Introduction (15 mins.)

·      A brief welcome and overview of the session

·      A concise summary of the article’s key points and arguments

·      Sharing the sentences in the article that intrigued you

2)   Guided Discussion (30 mins.)

·      Discussions around the guiding questions provided pre-meeting

3)   Wrap-up & Closing (15 mins.)

·      Summarize key takeaways

·      Final thoughts

·      Next steps

If you have any questions, please don’t hesitate to contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.

Looking forward to an engaging and insightful discussion with you!

Best regards,

Ezgi
INTRA Tax Reading Group 

Tax Reading Group (02/25)

How to Prepare

1)  Read the article in advance: “The Tax Treaties Myth”  

2)   Think about one or two sentences in the article that intrigued you.

3)   Reflect on these guiding questions:

·   The article critiques tax treaties as disproportionately benefiting capital-exporting nations and multinational enterprises. Currently, the UN is pushing for a new multilateral tax convention that aims to reshape global tax governance, potentially shifting its influence away from the OECD. This initiative challenges long-standing assumptions that tax treaties, primarily shaped by OECD countries, are necessary for global tax coordination. Given this, do you think a UN-led tax convention could address the equity concerns raised in the article?

·  The author questions the prevailing assumption that unilateral devices would cause undesired global tax consequences. The OECD’s Multilateral Convention on Pillar One’s Amount A aims to reallocate taxing rights to market jurisdictions, while many countries have implemented unilateral measures such as Digital Services Taxes (DSTs) to capture revenues from digital businesses. Given the current circumstances of international taxation, does the conventional assumption that unilateral measures are detrimental still hold true in today’s tax landscape?

·   The article suggests that developing countries often prioritize attracting investment over maximizing tax revenue. If this assumption holds true, how should a global tax governance structure be designed to balance the need for investment incentives with fair revenue collection? Should international tax rules be tailored differently for developing and developed countries, or is a uniform framework the best approach?

Meeting Format

1)    Welcome & Introduction (15 mins.)

·      A brief welcome and overview of the session

·      A concise summary of the article’s key points and arguments

·      Sharing the sentences in the article that intrigued you

2)   Guided Discussion (30 mins.)

·      Discussions around the guiding questions provided pre-meeting

3)   Wrap-up & Closing (15 mins.)

·      Summarize key takeaways

·      Final thoughts

·      Next steps

If you have any questions, please don’t hesitate to contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.

Looking forward to an engaging and insightful discussion with you!

Best regards,

Ezgi
INTRA Tax Reading Group 

Welcome to the Upcoming Tax Events section, where you can stay informed about the latest event updates in the field of taxation. In this section you can check the call for papers and conferences.