Direct Taxation, Tax Treaties and IIAs: Mixed Objectives, Mixed Results
Bibliographic record
Abstract
Tax treaties and international investment agreements (“IIAs”) have much in common. They share the same purpose of facilitating foreign direct investment (“FDI”), and they provide similar legal protections, such as prohibitions of discriminatory treatment of non-nationals and access to binding dispute resolution. Among other objectives, they are intended to reduce risk and create security and predictability, allowing investors to plan and carry out commercially viable activities under the protection of an international legal regime . In this sense, they both contribute to ensuring the sustainability of FDI and the legal regimes that support it. There are other similarities as well. Tax treaties and IIAs have proliferated in tandem during the recent period of intensified globalization. Indeed, they are often negotiated with the same country in close temporal proximity. The same international organizations, the OECD and the UN, have been instrumental in setting standards and drafting models. This chapter examines the interaction of tax treaties and IIAs from a Canadian and international perspective.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.083 | 0.149 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.003 | 0.002 |
| Bibliometrics | 0.013 | 0.026 |
| Science and technology studies | 0.004 | 0.009 |
| Scholarly communication | 0.029 | 0.017 |
| Open science | 0.003 | 0.008 |
| Research integrity | 0.004 | 0.007 |
| Insufficient payload (model declined to judge) | 0.016 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".