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Full-Text Articles in Law
A Global Treaty Override? The New Oecd Multilateral Tax Instrument And Its Limits, Reuven S. Avi-Yonah, Haiyan Xu
A Global Treaty Override? The New Oecd Multilateral Tax Instrument And Its Limits, Reuven S. Avi-Yonah, Haiyan Xu
Michigan Journal of International Law
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3 discusses the purpose of tax treaties in the twenty-first century, because it can be argued that they are less necessary under conditions of tax competition. Section 4 raises the question whether tax treaties can be improved short of a full-fledged multilateral tax treaty by inserting a most favored nation (MFN) provision similar to those found in bilateral investment treaties. Such an MFN provision operates over time to create a de facto multilateral treaty without the negotiation of one. Section 5 concludes this article.
Innovative Approach To Anti-Beps And The Coherence Of International Tax Law, Haiyan Xu
Innovative Approach To Anti-Beps And The Coherence Of International Tax Law, Haiyan Xu
SJD Dissertations
This dissertation is comprised of three articles:
- Avi-Yonah, Reuven,. co-author. "Evaluating BEPS: A Reconsideration of the Benefits Principle and Proposal for UN Oversight." H. Xu, co-author. Harv. Bus. L. Rev. 6, no. 2 (2016): 185-238
- Reuven S. Avi-Yonah & Haiyan Xu, A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits, 39 Mich. J. Int'l L. 155 (2018).
- Avi-Yonah, Reuven S. "China and BEPS." Haiyan Xu, co-author. Laws 7, no. 1 (2018): 4-30.