Can a multilateral negotiating process—that is, cooperation between many states in a single forum—successfully reform the network of bilateral tax treaties that currently makes up the bulk of international tax law? The BEPS Project aims to be the first major push for a multilateral tax process since the creation of the OECD’s Model Tax Convention in the 1960s. Through BEPS, the OECD and 130-plus countries are in final negotiations to implement Pillar One and Two, which will: (1) create a new taxing right for “market jurisdiction” countries on the profit of international companies that do business there without a physical presence; and (2) implement a top-up tax levied against companies that offshore profits from intangible assets in low-tax jurisdictions. To predict whether the multilateral reform effort will be successful, it is important to examine the nature of the multilateral negotiating process itself, because every negotiation is shaped by its context.  But this context is not static—rather, the nature of tax multilateralism varies depending on certain global conditions. Sometimes, it is a hierarchical process, dominated by powerful countries operating in a closed-club of developed states spearheading the effort, while weaker countries must tag along and accept the eventual outcome. Alternatively, multilateralism may be egalitarian and inclusive, with many countries—strong and weak alike—contributing to the debate, accepting tradeoffs, and endorsing the outcome. In this thesis, I demonstrate that the nature of tax multilateralism has changed from the former model to the latter by comparing the negotiation of the OECD Model Tax Conventions with the Pillars Negotiation. I begin by identifying several factors that influence the nature of tax multilateralism: first, the distribution of global power among states; and second, the level of integration of the global economy. In an international system where power is concentrated in a few states, and the international economy is fragmented (i.e., the conditions of the 20th Century), multilateralism tends to be hierarchical and exclusive. However, when power is diffused and the global economy is integrated, (the conditions of the 21st Century), then multilateralism is egalitarian and inclusive. In such a context, international tax issues—like base erosion and profit-shifting—are so vast and complex that no state, acting alone or in a small group, could deal with them. The thesis thus concludes that the nature of tax multilateralism has changed, because in modern negotiations, powerful states are both less capable of dominating other states in the negotiating process and are highly dependent on a successful outcome that creates global consensus.

Diploma thesis is trying to describe and analyse factors shaping current relations between China and Japan. My intention is to identify main factor, which shape and influence bilateral Sino-japan relations in long term view. I suggest that main factor is historical factor. Thesis explains the change in bilateral relations after Cold war. Also explains national myth-making, nationalism and current problems such as Yasukuni Shrine and text-book controversy. Last part is focused on territorial conflict between China and Japan, namely Senkaku/Diaoyu islands.

Au cours de cette étude, nous avons cherché  à déterminer le niveau et les moyens de la puissance sud-coréenne. Nous nous sommes demandés si la Corée du Sud ne pourrait pas se présenter comme un État pivot capable de faire le lien entre des états ou des partenaires antagonistes, aussi bien en Asie du Nord-Est qu’en Asie du Sud-Est. Aussi après avoir examiné les moyens de la puissance sud-coréenne nous avons conclu que le pays était une puissance moyenne traditionnelle n’ayant pas encore acquis le statut de puissance régionale et qu’en ce sens elle constituait une puissance atypique. Confrontée aux trois grandes puissances que sont la Chine, les Etats-Unis et le Japon, la Corée du Sud ne dispose que d’une marge de manœuvre très étroite pour affirmer sa présence internationale. Le développement de sa présence en Asie du Sud-Est est donc devenu en l’espace de quelques années un impératif de sa politique étrangère du pays. A l’instar du Japon d’après-guerre, le Sud-Est asiatique constitue une aire d’apprentissage privilégiée pour la diplomatie sud-coréenne et pour son action extérieure. / In this study, we tried to determine the exact level and means of the South Korean power. We wondered if South Korea could present itself as a pivotal state that is able to bridge antagonistic partners, both in Northeast and Southeast Asia. After considering the aspects of the South Korean power we concluded that the country is a traditional middle size power that has not yet acquired the status of regional power. In that sense the country is an untypical power. Facing three major powers such as China, the United States and Japan, South Korea has only a very narrow latitude to establish its international presence. Therefore developing its presence in Southeast Asia has become in just a few years an priority of its foreign Policy. For South Korea Southeast Asia is a privileged place where to learn and to develop its own external action, like it was for the post war Japan. Eventually, a unified Korea with the North Korean nuclear arsenal could weigh as much as demographically declining Japan. However as long as the anachronism of the separation will remain, South Korea will continue to grow alone regionally and in the international stage and will seek for external alliances.

The dissertation provides an analysis, evaluation, and comparison of selected areas of economic policy in the United States of America and Germany from 1933 to 1939 within the context of the 1920s, the Great Depression, and the Second World War. Based on a thorough analysis of the determined objectives, tools, the intended and unintended impacts of their fiscal policies, monetary policies, and foreign-trade policies, the dissertation thesis aims to verify the basic hypothesis that the United States and German economic policies were largely similar as responding to similar issues that both advanced economies had to face. During the verification process, the author relies mainly on the genuine processing and analysis of original statistical sources. In the individual chapters of the dissertation both identical, and also different features in selected types of economic policies are presented. On the basis of a comparison of the main economic-policies trends, despite some differences in the partial characteristics of chosen economic policy types, it can be concluded that economic policies of the central governments of Germany and the United States of America were similar in surprisingly many respects.

The PhD. dissertation Written Voice examines how Walt Whitman and Henry Miller through books, confined textual products of modernity, strive to awaken the reader to a more perceptive and courageous life, provided that the reader is willing to suspend hermeneutics of suspicion and approach Leaves of Grass and Tropic of Cancer with hermeneutics of hunger. This is examined from linguistic, anthropological and theological vantage point of oral theory (M. Jousse, M. Parry, A. Lord, W. Ong, E. Havelock, J. Assmann, D. Abram, C. Geertz, T. Pettitt, J. Nohrnberg, D. Sölle, etc.). This work thus compares Leaves (1855) and Tropic of Cancer examining their paratextual, stylistic features, their genesis, the phenomenology of their I's, their ethos and story across the compositions. By "voluntary" usage of means of oral mnemonics such as parallelism/bilateralism (Jousse) - along with present tense, imitatio Christi and pedagogical usage of obscenity - both authors in their compositions attack the textual modern discourse, the posteriority, nostalgia and confinement of literature, restore the body, and aim for futurality of biblical kinetics. It is the reader's task, then, to hermeneutically resurrect the dead printed words of the compositions into their own "flesh" and action. The third part of the thesis...