Interpretation of the safeguard clause in investment contracts Receivables on reflective losses of investment contracts David Gaukrodger`s EN, 2020 In summary, the latest developments have made the system increasingly complex and diverse. Although the main elements of AI are similar in most agreements, the details of these provisions can be considerably different. All this makes it increasingly difficult for countries, especially developing countries, to interact with inter-institutional agreements and also complicates the negotiation of new agreements. The main objective of international tax treaties is to regulate the distribution of global income taxes of multinationals between countries. In most cases, this means abolishing double taxation. The substance of the problem lies in the differences of opinion between countries on who is responsible for the taxable income of multinationals. Most of the time, these conflicts are dealt with by bilateral agreements that deal exclusively with income taxation and sometimes on capital. However, in the past, some multilateral tax treaties and bilateral agreements dealing with taxation and other issues have also been concluded. Preferential trade and investment agreements (PTIA) are broader economic agreements between countries concluded to facilitate international trade and the cross-border transfer of inputs. These may include economic integration agreements, free trade agreements (FAs), Economic Partnership Agreements (EPAs) or other similar types of agreements covering, among other things, foreign investment provisions.
In PTIA, the foreign investment section is only a small part of the contract, which usually includes one or two chapters. Other topics covered in the PTIA include trade in goods and services, tariffs and non-tariff barriers, customs procedures, specific rules for certain sectors, competition, intellectual property, temporary entry of people and much more. PTIA follows trade and investment liberalization as part of this broader priority. Often, the structure and appearance of the chapter on foreign investment is similar to a bit.