The U.N. Model Tax Convention’s Attempt to Override Investment Treaties: A Critical and Normative Assessment
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The U.N. Model Tax Convention’s Attempt to Override Investment Treaties: A Critical and Normative Assessment
Robert Danon and Adolfo Martín Jiménez examine the new model clause for article 25 of the U.N. model tax convention, arguing against introducing it in double tax treaties because it is inconsistent with modern investment treaty policy and a "whole of government" approach and raises several problems under international law.
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