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8 Disp. Resol. Int'l 63 (2014)
The Regulation of Tax Matters in Bilateral Investment Treaties: A Dispute Resolution Perspective

handle is hein.journals/disreint8 and id is 65 raw text is: 63 The Regulation of Tax Matters in Bilateral Investment Treaties: A Dispute Resolution Perspective Maira de Melo Vieira* Introduction The current international tax regime is based on a complex, well established, widespread and fairly coherent network' of more than 2,300 bilateral and multilateral tax treaties - the former representing the immense majority of them - covering more than 180 countries and territories. Most of these treaties were drafted from a combination of the provisions of the OECD Model Convention on Taxation and those of the United Nations Model Double Taxation Convention between Developed and Developing Countries (the 'United Nations Model Convention'), with variations that reflect the specificities of the relationship between the contracting parties. For the sake of comparison, these numbers are slightly higher than those of the international investment bilateral treaty network.2 * Associate, Wald (Sao Paulo, Brazil). LLB, major in Corporate Law (Corporate and Tax Management), University of Sdo Paulo (Brazil). Master (I) in Business Law, University of Aix-Marseille III (France). PhD Candidate in International Law, University of Sio Paulo (Brazil). The author is grateful to Professor Yariv Brauner, from the University of Florida Leuven College of Law (USA), ProfessorJose Augusto Fontoura Costa, from the University of Sio Paulo (Brazil), and Alexandre Sauveplane-Stirling (LLB, McGill University, Canada), for their valuable suggestions and comments to this article. The opinions and any mistakes contained herein are the author's own. 1 See YBrauner, 'International Trade and Tax Agreements may be coordinated, but not reconciled' (2005) 25 Virginia Tax Law Review 261. 2 UNCTAD, International Investment Agreements: Key issues, United Nations, New York and Geneva, 2004, Vol II, 210-211. Available at www.unctad.org/en/Docs/iteiit2004lOv2 en.pdf accessed 31 March 2013.

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