Double Tax Treaties: An Introduction

Double Tax Treaties and Their Interpretation

Bilateral Tax Treaties and GDP Comovement

Using a 30-year panel of quarterly GDP fluctuations from of a broad set of countries, we demonstrate that the signing of a bilateral tax treaty increases the comovement of treaty partners’ business cycles by 1/2 a standard deviation. This effect of fiscal policy is as large as the effect of trade linkages on comovement, and stronger than the effects of several other common financial and investm...

Clarifying the Meaning of ‘Beneficial Owner’ in Tax Treaties

and general language. Also, the discussion drafts do not clarify the context, object, and purpose to be considered in the interpretation of beneficial owner. Regarding the context, the drafts only explain that ‘‘the term ‘beneficial owner’ was added to address potential difficulties arising from the use of the words ‘paid to . . . a resident’ in paragraph 1,’’19 but they leave unspoken exactly ...

Algorithms for the Network Analysis of Bilateral Tax Treaties

In this thesis we conduct a network analysis of bilateral tax treaties. We are given tax data of 108 countries. Companies often send money from country to country via indirect routes, because then the tax that must be paid might be lower. In the thesis we will study the most important of these ‘tax’ routes. Questions that we will answer are, for example: 1. Which countries are the most importan...

Tax Treaties and Foreign Direct Investment: A Network Approach

Multinational investors often reduce tax on dividends by using indirect investment routes. This paper constructs a tax rate matrix to represent a real-world network of tax treaties between 70 countries and develops network algorithms to study the structure of tax-minimizing (direct or indirect) investment routes in the tax treaty network. The treaty shopping arbitrage rate, defined as the diffe...