Bilateral tax treaties govern host country taxation for most of the world's foreign direct investment (FDI). To explain why the tax rates used under these treaties are gradually falling we consider two-way capital flows with irreversible FDI. The extent of irreversibility determines the...

Bilateral international tax treaties govern the host country taxation for the vast majority of the world's foreign direct investment (FDI). Of particular interest is the fact that the tax rates used under these treaties are gradually falling although the treaties themselves do not specify any...