When examining the nature of disputes, it has to be kept in mind that the majority of disputes arise between the taxpayer and authority. Only rarely would a breach of a treaty obligation by one state lead to a dispute with the other contracting state. There are various mechanisms of dispute resolution at the international level, both for tax and non-tax disputes. Some of the most prominent measures for settling tax disputes are those found in DTCs and the EU Arbitration Convention. With most of the recent development focusing on Tax Treaty Arbitration, Mutual Agreement Procedure (MAP) remains the key tool to reduce treaty-related disputes. However, a number of other international adjudicatory bodies (namely, WTO, ISDS, CJEU, and ICJ) have had to review the legality of tax measures in light of international treaties. This trend gives rise to a number of practices such as treaty shopping, but also give an opportunity to a greater dialogue between international courts and more precisely, between these courts and tax tribunals.

• How do international courts (WTO, ISDS, CJEU, UN ICJ) approach tax measures?

• How frequently do these adjudicatory bodies deal with tax disputes? What is the typology of tax measures reviewed by these courts?

• What are the substantive and procedural interactions between trade, investment, and tax international courts?

• How does the global push to tax the digital enterprises relate to ICJ, WTO, ISDS?

• What is the impact of these courts’ decisions on tax law? How can one import terminology from other disciplines within the public international law practices (trade, tax, and investment)?

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