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The Effect of Treaties on Foreign Direct InvestmentBilateral Investment Treaties, Double Taxation Treaties, and Investment Flows$
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Karl P. Sauvant and Lisa E. Sachs

Print publication date: 2009

Print ISBN-13: 9780195388534

Published to Oxford Scholarship Online: May 2009

DOI: 10.1093/acprof:oso/9780195388534.001.0001

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Double Tax Treaties: An Introduction

Double Tax Treaties: An Introduction

The Effect of Treaties on Foreign Direct Investment

Reuven S. Avi-Yonah (Contributor Webpage)

Oxford University Press

This chapter discusses double taxation treaties (DTTs). The existing network of more than 2,500 bilateral DTTs represents an important part of international law. Current DTTs are all based on two models, the Organization for Economic Co-operation and Development (OECD) and United Nations (UN) model DTTs, which in turn are based on models developed by the League of Nations between 1927 and 1946. All DTTs are remarkably similar in the topics covered (even the order of articles are always the same) and in their language. About 75% of the actual words of any given DTT are identical with the words of any other DTT. Thus, the DTT network is the most important element of the international tax regime, that is, the generally applicable rules governing income taxation of cross-border transactions.

Keywords:   DTTs, international law, international taxation, income taxation, bilateral DTTs

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