International Tax Aspects of Sovereign Wealth Investors: a source State perspective

An increasing number of States have entered 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 thesis is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment.
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 fully 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.
The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.