The aim of this study is to clarify the historical premises of the establishment of the tax treaty between the UK and the US in 1945. Particularly, the UK-US treaty to prevent the international double taxation made an economic and political impact on the UK multinationals and the government. It was the first time that the UK government concluded a general tax treaty with elsewhere in the British Empire.

The problem of international double taxation on business income between UK and US occurred since the First World War. However, the UK government did not introduce a foreign tax relief for foreign investment to the US until 1945 because the government persisted to abhor reduction of the tax revenue. Thus, the tax issue became one of the causes that the British investment to the US had been sluggish. In addition, not a few UK multinationals were forced to change their organization alongside the tax environment during the period, raising cries of protest through some employer's associations such as the Federation of British Industries. The organizational changes like Phelps Dodge or Courtaulds sometimes influenced corporate long term investment strategy. Finally, the introduction of the American dividend tax in 1936 and the outbreak of the Second World War pushed the UK multinationals into further tax planning to alleviate the tax burden. The corporate behaviors and complaints of those firms made the UK government reconsider the tax regime of the interwar period. As a result, the general tax treaty between the UK and the US was concluded in 1945, a prototype of tax treaty of not only both countries but many countries in the Post Second World War.

抄録全体を表示

When the Lisbon Treaty negotiations started in the spring of 2007, an intense dispute arose over the legal status of the EU Charter of Fundamental Rights. While most states agreed on conferring legally binding force to the Charter, three states―the UK, Poland and the Czech Republic―expressed opposition to it. Amid the conflicting opinions, the Member States eventually worked out one political compromise: the Charter was to be given binding status but, in exchange, a ‘Protocol on the Application on the Charter’ was drawn up for these states. The Protocol, which is often referred to as on ‘opt-out’ or ‘exemption’ from the application of the Charter, is currently applied to the UK and Poland, and the Czech Republic is also to join them later.
Why did these three states oppose a legally binding Charter in the Lisbon Treaty negotiations? Their opposition is puzzling given that, back in 2004, these three states had accepted a legally binding Charter. Existing studies and newspapers report that domestic concerns these three states had led them to oppose the Charter. But, domestic factors are arguably not sufficient for a comprehensive understanding of why they opposed the Charter. The Charter was designed to codify the existing judicial practices of fundamental rights protection within the EU without amending the current competences of the EU. With such a guarantee, there should have been few concerns about the Charter.
The purpose of this article is to examine why these states opposed the Charter in the Lisbon Treaty negotiations. To this end, it stresses the need to look not only at domestic factors but also at EU level factors. EU level factors, which are considered in this article, refer to activities of the EU institutions, such as the Commission, the European Parliament and the European Court of Justice. Empirical examination shows that the activities of the EU institutions or behaviours of some members of EU institutions came into play as additional factors which strengthened concerns in these states about the Charter or which deepened their scepticism towards the EU. Therefore it is argued that, in combination with domestic factors, EU level factors, albeit in varying degrees and in different forms, were also involved in their opposition to the Charter.

抄録全体を表示

This article focuses on the decision-making process of Prime Minister Heath's administration toward the corporate failure of Rolls-Royce. I chose this process in light of the fact that modern airliner projects were too big to be managed by private corporations. I will examine not only the question, “Why did Rolls-Royce go bankrupt?”, but also “Why did the Heath administration leave Rolls-Royce to go bankrupt?”
In March 1968, Rolls-Royce made a contract for producing RB211 engines for Lockheed's TriStar airliners. At that time, Lockheed and Rolls-Royce expected the TriStar/RB211 to enjoy a monopoly in the medium-range wide-bodied airliner market. However, the expected production quantity for the RB211 had been shrinking. Rolls-Royce, therefore, could not absorb the escalation of the development costs of the RB211 project and, consequently, suffered a severe liquidity crisis. At the time of the first liquidity crisis in October 1970, the Heath administration pulled out of a commitment from the City as money lenders to Rolls-Royce. At the time of the second liquidity crisis in January 1971, the Heath administration decided to leave Rolls-Royce to go into bankruptcy. If the RB211 were to be cancelled, it would certainly cause the chain bankruptcy of Lockheed. As a result, Lockheed, the United States Nixon administration, the British Heath administration, and the United States bank group started negotiations over the continuation of the TriStar/RB211 project. By June 1971, the United States bank group agreed to provide a new $250 million loan to Lockheed subject to a debt guarantee by the United States government. With this new loan, Lockheed had the room to raise the price of the RB211 engines.
Faced with the crisis of this prestigious national corporation. the Heath administration did not bail out Rolls-Royce by limitless government financial commitment but rather ‘bailed in’ concerned business interests — namely, the City, Lockheed, and the United States bank group.

抄録全体を表示

Since 1980s, “European integration history”, which has been developed mainly by the European Community Liason Committee of Historians with using newly opend archives, has revealed many new historical evidences. Research on the relations between the Schuman Plan and Britain is one of the biggest issues of that development. However, the study on the “Eden Plan” has been rarely mentioned in the hitherto studies. The study on the Schuman Plan has been usually explained with the development of the Franco-German reconciliation. In this article, it was argued that the relationship between Britain and France was the most important aspect of the beginning of the European integration between 1948 and 1950. The Schuman Plan can be best understood by seeing the Anglo-Franco cooperation and conflict in the period. The year 1948 was marked by several important events such as the establishment of the Brussels Treaty, the Congress of Europe at The Hague, and Georges Bidault's plan on the “European Assembly”. Then in this avricle, the “Eden Plan” was discussed.
The “Eden Plan” tells us many important aspects of the relations between the Schuman Plan and Britain in the early 1950s. First, it can be said that Anthony Eden was much more constructive and supportive towards the Schuman Plan than Winston S. Churchill or Harold Macmillan, who were usually regarded as the eminent “Pro-European” Conservatives. Anthony Eden tried to save the Schuman Plan, while finding the best answer to link the British Commonwealth to the Schuman Plan. Eden's approach could be the best possible British plan to join the European integration movement planned by Monnet. However, because of the suspicion of Jean Monnet towards British Government's intention, Monnet refused this possible important contribution by British Foreign Secretary. With the failure of the two Monnet's plans of political integration, the European Defence Community and European Political Community, in 1954, Monnet faced the stalemate of his own approach without having Britain inside.
Thus, it is important to see the history of the relations between Britain and France from 1948 to 1954 to understand the beginning of European integration. Too narrow approach to study the Schuman Plan often ignores the origins of the Schuman Plan and the possible Britain's close relation to the plan. If Monnet showed a little more tolerance to Britain's approach, and if Britain showed a little bolder advancement to the integration, the later history of European integration should have been developed through the Anglo-France cooperation.

抄録全体を表示

What was British role in the making of the Lisbon Treaty? Is Britain still “an awkward partner” in the European Union? This article aims to examine British policy towards the European Union from the failure of the ratification of European Constitutional Treaty in 2005 to the signing of the Lisbon Treaty in December 2007.
Soon after the failures of the Treaty ratification both in France and in the Netherlands in June 2005, British Prime Minister Tony Blair declared to introduce “a period of reflection” to freeze the process of ratification. From the next month, Britain had hold the presidency of the European Council. Due partly to his domestic stalemate on the ratification, Blair exploited this opportunity to postpone difficult ratification of European Constitutional Treaty.
This difficulty originated in Blair’s decision for a referendum on the ratification of the Constitutional Treaty in April 2004. European Constitutional Treaty which was signed on 29 October 2004 caused a big political debate in Britain. Both the Conservative Party and Eurosceptic medias represented by Rupert Murdoch criticized the government for its intention to further transfer political power to Brussels. Having faced with this serious political difficulty, Blair naturally was “off the hook”. He simply felt “the waves of relief”.
Blair’s task was two-fold. First, he had to find a solution to this political stalemate as he would soon preside the European Council. Second, he was necessary to sell a new treaty to British people. To avoid a referendum, the British government needed to find a device which indicated that a new treaty was not “constitutional” one. In other words, a new treaty had to be a “reform treaty” without any new transfer of sovereignty.
A new French president, Nicolas Sarkozy, supported Britain to advance towards a “reform treaty”. Both French and British governments were contended with omitting any symbol of “federalism” or “constitution”. Within British government, it was generally agreed that Britain needed to defend the “red line” which prevented further transfer of power to the European Union. After having persuaded Angela Merkel, German Chancellor, Britain successfully secured the “red line”, and this meant that British government did not have to go into a national referendum. With this “success”, the EU could reach an agreement on the drafting of the Lisbon Treaty which would become signed in December 2007.
After the referendum crises of 2005, British government led the argument on the future of failed Constitutional Treaty. The answer was to save the essence of it by abandoning “federal” and “constitutional” features of the Treaty. This British policy was basically motivated by its own domestic rivalry on the future of Europe. Although Britain might be “an awkward partner” within the EU, the Labour governments tried to find out a way to go out of the crises of 2005 by abandoning some of hopes and wishes that people dreamed.

抄録全体を表示

This article will attempt to analyse the détente policy of the Harold Wilson government in the mid-1960s. The structure of the Cold War system began to significantly change from the 1960s. After the second Berlin crisis and the Cuban missile crisis, the intense confrontation that had up until this time characterized this conflict was mitigated by the fear of all out nuclear war, thus creating the first atmosphere of Cold War détente in East-West relations. At the same time, within both the Eastern and the Western alliances multipolarity was being promoted, as a result more states were able to contribute to the process of détente. This interconnectedness of détente and multipolarity affected the way the British government engaged in détente and alliance politics.
The 1960s saw British power decline in world affairs and the rise in power of the Federal Republic of Germany (FRG) in Europe, a situation that became a symbol of multipolarity in the West. To maintain influence in European Cold War politics, Harold Wilson's government pursued a purposeful improvement in relations with the FRG. Therefore, even if the Wilson regime had had its own prescription to the German problem, it could not talk to the East in disregard of the wishes of the FRG government. The continuation of the policy of non-recognition of the German Democratic Republic (GDR) as a second German state and the Order-Neisse line as the western border of Poland was the logical result.
This initiative taken by the Wilson government centred on the idea of a “declaration on Europe”, which was intended to establish a code of conduct applied to all signatory states with the aim of creating a better political atmosphere in East-West relations. It depicted, for instance, removal of restrictions on trade and promotion of cultural exchange with the East. Behind the idea lay the prospect that multipolarity would enhance the autonomy of the East European states vis-à-vis the Soviet Union. Due consideration was also paid to the FRG's special insistence on inserting the principle of self-determination in the draft text of the declaration. But the political circumstances were not suitable for the initiative to materialize. The Eastern insistence that the German problem had to be resolved to further détente through Western acceptance of the GDR and the Order-Neisse line, and the Western position that détente must be a pre-condition for the settlement of the German problem, effectively stalled the process of further detente.
This initiative by the Wilson government needs reappraisal in order to show not only how the British government possessed a forward looking idea to promote and further détente but such a reappraisal also demonstrates the degree to which the German factor regulated the British diplomatic line. In this vein, détente and multipolarity were two determining factors underpinning British détente policy in the middle 1960s.

抄録全体を表示

This article analyses policies considered within the British government in 1946 on two issues concerning Iranian oil—a new oil concession and a labour dispute against the British Anglo-Iranian Oil Company (AIOC)—to investigate how Britain tried to secure access to oil immediately after World War II.
Within the process of policy definition surrounding these two issues, it is possible to see both a search for new policy approaches and traditional ideas. In relation to these two issues, the British search for new policy approaches intended a new form of relations with the United States and Iran. At the same time, traditional ideas retained currency within British thinking and had a great impact on the policy definition process.
Britain intended co-operation with the United States to confront the potential threat of the U. S. S. R. in the process of obtaining a new Iranian oil concession. The Anglo-American co-operation which Britain aimed at, however, was one that would damage neither her independence nor her leadership position in the region, as Britain still perceived Iranian international relations within the traditional framework of spheres of influence in which Britain and the U. S. S. R. were the main actors. Further, as Britain regarded the role of the United States as no more than supplemental, rather than making use of the framework of Anglo-American co-operation in the labour dispute against the AIOC, Britain gradually inclined to unilateral policies employing bare power.
On relations with Iran, the British government on the one hand required the AIOC to give Iranian employees “equal treatment” with the British. On the other hand, plans for a joint Anglo-Iranian company symbolising “equal partnership” were soon rejected when she began discussions for the acquisition of a new oil concession. These apparently inconsistent attitudes can be explained by considering Britain's true intentions regarding equality. The real intention behind Britain's insistence on equal treatment by the AIOC was for the purpose of retaining the existing concession which had made it possible for Britain to secure access to oil. The equality pursued by Britain did not change the existing framework when it came to new concessions. Furthermore, the traditional image of relations with Iran can be seen in the despatch of an army brigade to Iraq and plans for direct involvement in the internal affairs of Iran.
It should not be overlooked that Britain was already searching for new policy approaches immediately after WWII. However, traditional ideas prevented her from implementing policies that would have brought about a drastic change in the international relations surrounding Iranian oil.

抄録全体を表示