Recent amendments to the United Nations (“UN”) Model Tax Convention aim at banning the use of investor-State dispute settlement (“ISDS”) provisions for disputing tax measures, thereby attempting to deal a further blow to international investment agreements (IIAs). The UN Model Tax Convention is regularly updated and was drafted with the aim to cater for the…

With Procedural Order No 4 on Bifurcation (hereinafter “PO 4”), the Tribunal of Alberta Petroleum Marketing Commission v. USA issued a decision on bifurcation at the request of the Respondent following, as many others, Glamis Gold. While in Glamis Gold the request to bifurcate proceedings was rejected, this Tribunal decided to grant the application. The…