Implementation of step 13 of the BEPS Action Plan in the context of introducing automatic exchange of information for tax purposes

The precondition for Ukraine's accession to the multilateral agreement on automatic exchange of interstate reports is the introduction of the Report by countries of the international group of companies (hereinafter - the intercountry report), which is part of the OECD-recommended three-tier transfer pricing documentation model (Action Plan 13, BEPS Action Plan 13). It has been proven that the implementation of the intercountry report is in the early stages of the implementation of Step 13(tax legislation establishes the obligation of multinational enterprises to submit such reports; the form and procedure for its preparation are designed , but there is no mechanism for ensuring confidentiality and appropriate use of information of such reports). The conclusion is made on the need to further improve the legislation of Ukraine in the field of international exchange of information for tax purposes and the relevance of research on these issues.

Does Ecuador Comply with International Tax Information Exchange Standards Required to Apply the Multilateral Agreement on Mutual Administrative Assistance in Tax Matters?

The exchange of tax information is essential to prevent fraud and tax evasion. Accordingly, states and international organizations have developed international conventions regarding the exchange of tax information. One example is the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Some States, including Ecuador, have signed and ratified this Convention. However, it is unclear whether Ecuador currently meets almost all Convention's requirements.In this article, I investigated the Ecuadorian regulations and showed that Ecuador complies with most of the Convention’s standards. However, Ecuador does not have a specific comprehensive law that regulates information exchange. Therefore, Ecuador should develop policies and norms that exclusively regulate tax information exchange to facilitate practical information exchanging with other tax authorities.

The Expansion of Shanghai Cooperation Organization: How can it Improve India-Pakistan Relations?

South Asia is one and only of the tiniest unified region in the world, with a consistent competition among India and Pakistan acting as a tentative wedge to regional cooperation through the SAARC. Nevertheless, India and Pakistan join the multilateral agreement; then both became permanent members of the Shanghai Cooperation Organization in 2017. Although, it is very initial to envisage that the rival relations of both countries influenced by the forum. This paper tries to explain alternative and possible openings for partnership in several ranges, especially in counterterrorism and security, which may be turning a positive influence on Indo-Pak relations. Further, the negative impression of India & Pakistan contentions on the SCO forum is very low, unlike SAARC. This research also seeks to explore the implications of SCO's engagements on the bilateral relations of India and Pakistan. These engagements may be about to resolve issues about the peace and stability in the nuclearized South Asia.

Foreign investment in the WTO

This article explores the application of the policy science concepts of ‘policy frames’ and ‘policy transfer’ as explanatory tools in the study of law and legal reform. It does so by examining the transformation in international law of foreign investment issues from a state-centred classical international law frame, within which foreign investment appeared as a property issue and protection of property as the central objective of law, to a market-centred neo-liberal frame, under which foreign investment is regarded as a ‘trade’ issue and growth-oriented liberalization of trade the central objective of law. This transformation can be summarised very crudely as the replacement of a discourse in which states have rights and multinationals have duties, by one in which states have duties and multinationals have rights. However, this transformation is neither complete, nor uncontroversial. This article considers recent efforts to launch negotiations for a multilateral agreement on investment within the WTO from this ‘framing’ perspective and concludes that framing analysis may have useful applications in the study of law.