The Resource Tax treatment of sovereign wealth funds

Tax treatment of sovereign wealth funds

Label
Tax treatment of sovereign wealth funds
Title
Tax treatment of sovereign wealth funds
Creator
Subject
Language
eng
Summary
Sovereign Wealth Funds (SWF) do already exist for decades. Generally speaking most attention was given to these funds not because of their tax treatment rather than for political reasons, including the fear of countries to lose control over some companies being engaged in one or the other key industry if taken over by a foreign SWF, which also led to regulatory discussions. But not every information regarding SWF produces a critical atmosphere, in particular, as it may lead to economic benefits for the country in which the investment is made. For example the Maldives, whose cabinet already met underwater, had announced to establish a SWF, seeking to buy a new homeland in the case the population will become environmental refugees because of the climate changes leading to a flooding of these Islands. It also remains to be seen whether the traditional premiere league club Manchester United will be able to defeat the Spanish favourites Real Madrid and Barcelona in the fight for the champion's league trophy after being taken over by a Qatari SWF, providing a tidy transfer amount to spend on new players. Nevertheless especially when these SWF were engaged in cross-border transactions, comprising a broad range of activities, questions did arise, whether and under which conditions these investment vehicles might benefit from tax conventions. The 2010 Update of the Commentary on the OECD Model Convention (MC) includes some clarification on the application of the Model Convention to States, their subdivisions and their wholly-owned entities. After an overview of IFA activities in this respect, the concept of SWFs is explained. Emphasis is put on the tax treatment of the income derived by these funds, from a domestic and treaty perspective, taking into account the changes of the Model Commentary. As a special point of interest the doctrine of sovereign immunity and its influence on taxation, which is predominantly underlying the discussion on the treatment of SWFs, is analyzed from a jurisdictional and procedural perspective
http://library.link/vocab/creatorName
Goeydeniz, S
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IFA Research Paper
http://library.link/vocab/subjectName
  • sovereign wealth fund
  • tax treaty
  • sovereign immunity
Label
Tax treatment of sovereign wealth funds
Instantiates
Publication
Extent
27 p.
Label
Tax treatment of sovereign wealth funds
Publication
Extent
27 p.

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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