Member of the Turkish delegation for tax treaty negotiation.

Extensive experience in negotiation of bilateral tax treaties.

C. The distinction between bilateral and multilateral treaties

That is certainly true with respect to a number of bilateral treaties.

The following are significant issues with regard of exchange of information clauses in tax treaties

Modern practice regarding the length of treaty suspension no longer focuses on the distinction between bilateral and multilateral treaties.

Many States were parties to a number of bilateral, regional and multilateral treaties and many provided lists of such treaties.

The Vienna Convention provides the following rules on the interpretation of treaties, both bilateral and multilateral

The practice of States relating to the consular provisions in bilateral treaties is not very coherent.

The Vienna Convention on the Law of Treaties provides the following rules on the interpretation of treaties, both bilateral and multilateral

There seems in theory no reason why such treaties should not stand on the same footing as bilateral treaties between the belligerents.

It would be helpful if LDCs could have further bilateral and multilateral treaties.

A similar question arises when the distinction between bilateral and multilateral treaties is given prominence.

In furthering the contributions to the network of international arrangements, bilateral investment treaties continued to expand.

Thus, although following both World Wars multilateral treaties were still viewed as more resilient than bilateral ones, an increased resilience of bilateral treaties was acknowledged.

The term is defined in many income tax treaties and most European Union Value Added Tax systems.

(a) The irrebuttable presumption, based upon State practice, that bilateral treaties are terminated, subject to express provisions indicating the contrary

In the opinion of the Special Rapporteur, the principle is not in fact a general principle, being formulated exclusively in relation to bilateral treaties.

Such treaties form a very important class of international transactions and form the precursors of the more recent bilateral investment treaties.

Professors Daillier and Pellet adopt the position that the peace treaties of 1919 and 1947 confirm the principle of abrogation in the case of bilateral treaties.

Finally, whereas it was traditionally understood that armed conflict had a greater effect on bilateral treaties than on multilateral treaties, there is strong evidence that this distinction has diminished.

In the area of narcotics control, multilateral treaties remained operative between all countries except Germany, where they were suspended bilateral treaties between belligerents, however, were at least suspended by the war, and it is possible they were terminated .

The EU also needs common initiatives to replace piece meal bilateral agreements on tax evasion and tax havens, which undermine the goal of a fair society.

Even in the case of those bilateral treaties intended to establish a permanent condition of things, there is nothing to prevent a victorious belligerent from dissolving them in the peace treaty.

Italy s Taxing Election

Reforming tax systems

For example, C. W. Jenks argued that i t is now generally admitted that war has not the same effect on multilateral legislative treaties as upon bilateral contractual ones. Similarly, Robert Tucker argued that

In considering the effects of war on treaties it is useful, and probably necessary, to distinguish between those treaties having a large number of states other than the belligerents as parties and bilateral treaties having as signatories only the belligerents.

That's why our existing policies are so upside down.

In January 2004, the OECD released a discussion draft on whether the current tax treaty rules for taxing business profits are appropriate for e commerce.

In discussing the effect of armed conflict on treaties, commentators have attempted to distinguish between bilateral treaties, as more susceptible to suspension or abrogation, and multilateral treaties, as more resilient.

Rather than adopting the former multilateral bilateral distinction, several modern commentaries on the effect of armed conflict on treaties adopt a more nuanced approach, looking to the actual subject matter of the treaty rather than the number of parties.

It means bilateral discussions instead of bilateral threats.

Custody, registration and publication of treaties Treaty Section

Provisions on minorities contained in such treaties and other bilateral arrangements should be based on universal and regional instruments relating to equality, non discrimination and minority rights.

Again, when comparing the replies concerning bilateral and multilateral treaties, the figures were similar for mutual legal assistance and for extradition.

Previous positions include Director, International Tax Relations, Tax Policy Department Director, Tax Department, Italian Banking Association and Economic Adviser to the Minister of Finance for international tax policy and financial tax issues.

205.0 Bilateral sources 166.0

325.0 Bilateral sources 530.0

Bilateral Multilateral

28 Bilateral investment treaties which include bonds in the definition of investment can lead to claims against debtors for expropriation in the context of debt restructuring.

(b) Report of the Committee on the Elimination of Discrimination against Women on its thirty second session (A 60 38 (Part I))

1996 Fair Taxation System, Aleppo.

The legal basis for extradition is the bilateral treaty mentioned above in reply to subparagraphs 3 (a), (b) and (c) of Council resolution 1373 (2001).

The most significant recent development is that exchange of information provisions in tax treaties should override bank secrecy and other confidentiality laws in the transmitting State.