Uluslararası Vergi Uyuşmazlıklarının Uluslararası Yatırım Tahkimi Bağlamında Değerlendirilmesi

The arbitration of international tax disputes is a controversial and developing area of international law. Although the conclusion of double taxation avoidance agreements (DTAs) between States has paved the way for the development of arbitration in international tax dispute resolution, the arbitration procedure provided under the existing international treaties for the resolution of cross-border tax disputes continues to have significant limitations that may hinder the effective resolution of disputes, such as subject matter, time, amount in dispute and the existence of various procedural prerequisites, compared to the current international arbitration practice in commercial disputes. In this context, international investment arbitration, whose jurisdiction is established through bilateral investment treaties (BITs) concluded by States for the protection of foreign investments, emerges as an alternative dispute resolution …

Keywords:…

International Tax Law, International Investment Arbitration, International Tax Disputes, Double Taxation Agreements (DTA), Bilateral Investment Treaties (BITs)…