nciple has been affirmed in a series of United Nations resolutions and declarations (United Nations Conference on Trade and Development, 1996).
Countering this principle of international law, however, European Union Directive 88/361/EEC calls for the abolition of all restrictions to the movement of capital and includes in the definition of capital movements a wide variety of direct investments, including the establishment of new undertakings, the acquisition of established undertakings, and the participation in new or established undertakings (Brewer & Young, 1995a). Free trade agreements between (1) Australia and New Zealand and (2) Canada, Mexico, and the United States·the North American Free Trade Agreement (NAFTA) also have included provisions governing foreign investment (Brewer & Young, 1996). The Australia-New Zealand agreement, which did not specifically regulate FDI in the initial agreement, was amended later to add a protocol liberalizing trade in services, subject to
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