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Territorial Dispute (Libya/Chad) , Judgment of 3 February 1994, ICJ Reports 1994, pp. 21–22, para. 41. In any case, a different customary international law existed in 1962, when the International Law Commission (ILC) initiated work aimed to codify international rules on treaty interpretation. If claims are made that the rules laid down in Articles 31–33 of the VCLT are identical with customary rules on treaty interpretation, consequently, this cannot explain why Articles 31–33 are always relevant for the interpretation of tax treaties concluded by Sweden. An additional

any- thing else, we need to understand the role of party inten- tion. To gain this understanding, we need to establish the aim of the treaty interpretation process assumed by Ar- ticles 31–33. When tax lawyers describe the relevant in- ternational law, they often maintain that Articles 31 and 32 stand for two different approaches to treaty interpreta- tion.16 As they articulate it, Article 31 requires the adop- tion of a textual (or objective) approach whereby, when applying Article 31, interpreters consequently inquire into the meaning of the text of treaties.17

cannot be obtained quickly. Accordingly, the Anti-Tax Avoidance Package, including the ATA Directive, should represent a pragmatic approach that sets out initiatives, which can take effect prior to agreement and introduction of the CCCTB. Having the aim of combating tax avoidance practices that directly affect the functioning of the internal market, the ATA Directive, thus, lays down anti-avoidance rules in the following six specifc fields: deductibility of interest, exit taxation, a switch-over clause, a general anti-avoidance rule (GAAR), the CFC rules, and rules to

of general rules known as formal law, and excludes legislation either directly aimed at particular people, or at enabling anybody to use the coercive power of the state for such discrimination. It means, not that everything is regulated by law, but, on the contrary, that the coercive power of the state can be used only in cases defined in advance by the law and in such a way that it can be foreseen how it will be used ( Friedrich August Hayek, 2006 ). but in all state actions that have effects on a whole nation. Even though Hayek’s idea on that kind of

Abstract

Decisions to invest, withdraw, or transfer capital in different foreign markets have become a fixed part of management pragmatics in contemporary companies. The results of the 2017 Global Corporate Divestment Study show that multinational enterprises (MNEs) from particular parts of the world tend to see the main reasons behind their decisions on FDI (foreign direct investment) and FD (foreign direct divestment) in a slightly different manner. Insofar as internationalization processes and FDI have been relatively thoroughly studied and discussed in world and Polish literature, the concept of de-internationalization pursued through the prism of divestment still requires further analysis and consideration. The article aims to present the general framework of the process involving FDI, FD, and the major factors behind it in Poland and Latvia. Theoretical considerations are supplemented with the analysis of statistical data coming from the UNCTAD database as well as the database of Poland’s and Latvia’s central banks, illustrating foreign investment flows. The article uses the method of critical analysis of world and Polish literature, analysis of reports on relevant issues, and desk research analysis.

decision according to their national rules. We made proposals that are as ambitious as possible, but as pragmatic as needed to achieve gradual improvements already for the 2019 European elections. It is unfortunately true that the connection between national parties and their affiliated European political parties has not been sufficiently presented to the electorate in the past and their visibility remains low. The goal of the current reform proposal is to break the deadlock, by giving European Political Parties a greater appearance in electoral campaigning. This

sustainable common security. Too many of our dominant systems – capitalism, climate, democracy, sovereign states, even the international security system – are stressed, if not dysfunctional. Similarly, decline is apparent in the world order, the neo-liberal order, Pax Americana and the transatlantic post-war alliances. Rather than plan a coherent transformation, officials still prefer pragmatic, incremental reforms to existing arrangements (e.g. the tippy-toe approach). Like it or not, our diverse global systems and challenges tend to be “linked