International Tax Aspects of Sovereign Wealth Investors: A Source State Perspective

International Tax Aspects of Sovereign Wealth Investors is the first in-depth analysis of the international tax aspects of sovereign wealth investors that serves as a comprehensive guide to designing tax policy, from a source State perspective, towards inbound sovereign wealth investment. Activity by sovereign wealth investors has grown in recent years, with increasing number of States entering the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors has attracted growing and wide attention. This book considers commonly accepted international tax policy principles and is a conceptual framework that will assist source States in introducing new tax policy and in evaluating or reconsidering their existing tax policy analysis in relation to foreign sovereign investors.

What’s in this book:
Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author thoroughly addresses the following aspects of the subject:

• the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors;
• tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and
• the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors.

How this will help you:
As a comprehensive and a unique guide to important issues concerning the international taxation of foreign sovereign wealth investors, this book is beneficial to tax policymakers, practitioners, academics and (home States of) sovereign wealth investors who will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.