Research Topic. Title of selected research
Research Topic. The supervisor and student shall choose a topic or topics that are appropriate for research at a high level and that are geared to enriching human knowledge and to advancing science in accordance with the research tradition of the Hebrew University. The Obligation of the Supervisor: To educate and guide the student as a researcher and as a scientist, as a member of the scientific community and as a person contributing to society and humanity; to serve as a model for ethical scientific activity; to provide an intellectual, challenging and enriching environment and to be a teacher and a partner; to relate to the supervision as a dialogue between two; to respect the student; to listen to her/his views and to encourage her/his independence and her/his creativity; to accept the fact that sometimes a seemingly erroneous idea of the student may turn out to be correct; to provide the student with ample time for consultation; not to relate to the student as only fulfilling instructions and not to request the student to do additional tasks that are not related to the research work; to educate and guide her/him in the intricacies of scientific writing, both those required for writing a doctoral dissertation and those required for scientific publications; to assist the student in an ongoing manner and particularly at times of distress in the research; to encourage her/him to participate in conferences and other academic activities; to accompany her/him on her/his way upon completion of the doctoral dissertation. The Obligation of the Student: To acknowledge that when choosing a research topic she/he undertakes a great responsibility to promote it; to devote her/his best energy and time for carrying out the research work, while paying attention to the guidance of the supervisor; to act in close cooperation with her/him; to respect the experience, criticism and views of the supervisor but to suggest, when needed, alternate approaches; to ensure the ethical rules of the work and scientific reporting; to act responsibly towards the agent funding the research; to promote relations of mutual respect and cooperation with other students in the supervisor’s laboratory; to make available the laboratory notebooks, data collections and other research recordings for the perusal of the supervisor at all times and to give them to the supervisor upon completion of the doctorate.
Research Topic. The previous analysis revealed that the paradigm of linguistic nationalism, which had shaped treaty making since the second world war, has been largely transcended and replaced by a new paradigm of English as dominant lingua franca for tax treaties. Since the conclusion of my study, the OECD has issued the BEPS multilateral instrument,1 which modifies a large num- ber of treaties. As of 22 March 2018, seventy-eight countries have signed the MLI and six more have expressed their intent to do so.2 The MLI turns out to be a bilingual treaty with equally authentic English and French texts: In witness whereof the undersigned, being duly authorised thereto, have signed this Convention. Done at Paris, the 24th day of November 2016, in English and French, both texts being equally authentic, in a single copy which shall be deposited in the archives of the Organisation for Economic Co-operation and Development.3 On the face of it, the policy implemented by the MLI appears as a comprom- ise solution in view of the linguistic heterogeneity of the global tax treaty network; however, the question arises whether the MLI really implements the optimal policy available given the linguistic and political realities and, if not, what can be done to improve it. This Annex will evaluate the MLI final clause on the basis of the research presented in the previous chapters. In the course of this, possible ways to remedy its deficiencies will be discussed. 1Henceforth referred to as MLI. 2xxxx://xxx.xxxx.xxx/tax/treaties/beps-mli-signatories-and-parties.pdf. 3OECD, Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, Article 39. The French text is equivalent and reads ‘Fait à Paris, le 24ème jour de novembre 2016, en anglais et français, les deux textes faisant également foi, en un exemplaire unique qui sera déposé aux archives de l’Organisation de coopération et de développement économiques.’ OECD, Convention multilatérale pour la mise en œuvre des mesures relatives aux conventions fiscales pour prévenir le BEPS (Paris: XXXX Xxxxxxxxxx, 2016), Article 39.
