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Paper Instructions:

Comparative International Tax Law Coursework 

Scotia is a small state, which has recently emerged from a long term union with its neighbor Anglia, which was known as The Unitary Kingdom. A full system of Double Tax Relief (DTR) Conventions remain in place post secession which follow the form of the OECD Model. 

Scotia has significant oil, gas and renewable energy resources both onshore and offshore, and is keen to preserve them and redesign it’s regulatory framework to ensure a sustainable but profitable energy management policy.

However Scotia has become concerned about the way some individuals and corporations from beyond its boundaries are using its existing system of treaties and is also keen to encourage new investment in its energy sector. It is anxious to instigate reform. 

You are engaged by the First Minister of Scotia and asked to make recommendations for a new fiscal regime and set of regulatory measures. 

Write a report in response to this brief. In particular you are asked to consider:-
1.    To what extent should Scotia keep its current system of DTR Conventions?
2.    What best practice ideas should Scotia adopt for the fiscal regulation of its energy sector, both onshore and offshore?