In 2013 the OECD released its 15-point action plan to deal with base erosion and profit shifting (BEPS), which recognised that BEPS has a significant effect on developing countries because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote...

This paper explores the question whether entering into double tax treaties leads to more foreign investment. The topic has been the subject of a number of studies that have generated inconsistent results. The paper reviews previous studies and notes the limitations that may have affected their...

Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

Chinese double tax treaties define the territory of China in a broad sense and prima facie Hong Kong is included within the territory of China. However, the Chinese and Hong Kong authorities, as well as all of China's treaty partners, take the view that Hong Kong is not covered by Chinese tax...

This article examines tax treaty trends in five Central Asian Republics: Kazakhstan, the Kyrgyz Republic, Tajikistan, Turkmenistan and Uzbekistan, following the gaining of their independence after the fall of the Soviet Union in 1991. In particular, it compares the construction of treaties...

China attracted considerable foreign investment following the opening of its economy in 1979. With the switch to a quasi-market economy, China became reliant on taxes to fund government, opening the door to potential double taxation of profits from foreign investment, first in China and second...