Among other things, there is a need to improve the transparency of ISDS procedures, for example by publishing documents allowing access to the procedure. Legal concepts and definitions such as “indirect expropriation” and “fair and equitable treatment” need to be formulated more precisely. In addition, the ILO should provide for measures to protect against claims lightly as well as derogation clauses to protect the public interests of States. In current contractual practice, the prevention of double taxation requires the simultaneous application of two distinct approaches. The first approach is to eliminate the definitional congruences of concepts such as “domicile” or “income”, which could otherwise be the cause of double taxation. The second approach is exemption from double taxation by one of the three methods. The imputation method makes it possible to set off foreign taxes against the tax paid in the country of residence. . .

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