The Impact of International Tax Treaties for Avoidance of Double Taxation on Investments Flow “Comparison Study”

Afaf Ibrahim Ismail Mohamed;

Abstract


In the current era of cross-border transactions across the world, and the dynamism of international trade and commerce and increasing trans-border interaction among nations, and the widespread liberalization of economic policy which resulted in an increase in foreign direct investment (FDI). By encouraging foreign investors to enter international markets, many countries are witnessing exponential growth within their economies and local industries. The surge of FDI not only brings capital for emerging or growing industries, but it is also capable of boosting the country's economy by creating greater access to financing, more job opportunities, and potential knowledge and technology spillovers.

Realizing the importance of FDI role in boosting growing economies the European Union in its partnership Agreement with Egypt emphasized on the necessity of concluding double tax treaties with all the EU countries to boost and encourage its FDI which came clear in article 46 in the Partnership Agreement.
As double taxation considers one of the obstacles that hinders the movement of capital countries seek to conclude DTT , that’s why it is important to handle the issue of The Impact of international tax treaties for avoidance of double taxation on investments flow.

In this context this research is divided into three chapters all discuss the relation between concluding tax treaties and FDI furthermore illustrating the concept of both Investment and FDI.
Chapter one handles the following:
Section one: discusses the historical background of tax treaties that began in the nineteenth century and still renewed by both UN and the OECD.
Section two: this section handles the definition of Tax Treaties and its importance as they help eliminating double taxation which hinders the flows of capital and investments and it turned out that there are two points of views
First: Tax Treaties have no impact on FDI.
Second: Tax Treaties do affect FDI.
Section three: this section discusses the definition of double taxation concept, its kinds and remedies represented in the tax treaties.
Section Four: discusses the above mentioned emphasize from the EU to conclude tax treaties with Egypt to boost and encourage FDI which is mentioned in the Egyptian European Partnership.


Chapter two:
This chapter is divided into four sections and it discusses investment as follows:
Section One: discusses the following:
- Investment definition.
- Investment Types which are:
1- Individual investment.
2- National Investment and Foreign investment:
3- Autonomous investment.
4- Induced investment.
5- Real investment and financial investment.
Section two: discusses several points:
- FDI Concept.
- FDI Types which are:
1- Wholly Owned Subsidiary which some times called green field investment.
2- Merger and Acquisition.
3- Horizontal FDI.
4- Vertical FDI.
- FDI Importance.
- FDI Determinants which are:
1- Market Size and potential Growth.
2- Business Operating Conditions.
3- Governance.

- FDI Theories which divided into two main theories:

1- Traditional trade Theory: which is divided by its turn into :
- Ricardo : The Comparative Advantage Theory.
- Hecksher and Ohlin: The Factor Endowment Theory ( The Swedish Model).
- Leontief Paradox.
2- Modern Trade Theory which includes:

- The similarity of preferences Theory.

- The Imitation-Gap Theory.

- The Monopolistic Competition Theory.
3- Firm Theories which includes:
- The Market Imperfection Approach.

- The Product Life-Cycle theory ( Vernon).

- The Oligopolistic Approach.

- The Internalization Approach.

- Dunning’s Eclectic Approach.

Section Three: discusses the Egyptian Economic Performance and Foreign Direct Investment as follows:
- FDI in Egypt.
FDI in Egypt registered high levels until the fiscal year 2009/2010 as it declined due to the adverse effects of the global financial crisis. At the time Egypt was trying to overcome the results of the global financial crisis the net FDI in Egypt contracted by 67.6 percent, posting merely US$ 2.2 billion (against US$ 6.8 billion). This was mainly an outcome of the rise of 73.8 percent in capital repatriation to US$ 7.4 billion, and the decline of 13 per cent in total investment inflows to US$ 9.6 billion, due to the spillovers of 25th of January revolution during the fiscal year 2010/2011.

- The Current Status of European Investments in Egypt.
This point discusses the EU investments in Egypt and their development over a period starts from 2002/2003 until 2011/2012.

Section Four:
This section discusses two main points which are:
e) The historical developments for investments position in Egypt.

f) Investments Laws Developments and their potential impact on FDI.

Chapter three:

This chapter discusses the practical study from two approaches in two sections:

Section one: The theoretical approach.

Section two: The practical approach.
The practical approach represented in the Statistical Model which proved that Tax Treaties have an impact on FDI.


Other data

Title The Impact of International Tax Treaties for Avoidance of Double Taxation on Investments Flow “Comparison Study”
Other Titles أثر اتفاقيات تجنب الازدواج الضريبي و آثارها على تدفق الاستثمارات ( دراسة مقارنة- دول الاتحاد الأوروبي)
Authors Afaf Ibrahim Ismail Mohamed
Issue Date 2015

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