SWFs and taxation: National, bilateral and multilateral approach
Why this work is in the frame
A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.
Bibliographic record
Abstract
Taxes are, if not a driver, at least a critical factor for investors, when investing abroad. Sovereign Wealth Funds are not different from other investors in this respect. That notwithstanding, unlike operators, scholars have hardly paid attention to the 'SWFs' tax exemption factor'. Thus, there is still room for investigation and research. Some States exempt SWFs from paying taxes, according to a common practice and generally accepted principle that one government does not tax another. Scholars usually focus on US law and regulations, providing for a general tax exemption, but State practice is wide ranging, from exemptions applied to both commercial and non-commercial transactions, to both portfolio investments and FDI (UK), to exemptions limited to non-commercial investments (Canada) or to passive, portfolio investments (Australia); again, from a dual system, where exemption is granted by law to portfolio investments, and by the ministry of finance to FDI (France), to a general exclusion of exemption (Germany, Switzerland, Poland, Norway). A comparative analysis of both treatment and grounds for tax exemption applying to SWFs is carried out in Chapter 8. The existence of a direct or indirect relationship between tax exemption and State immunity (from jurisdiction) has been investigated as well. At a first glance, the two elements seem strictly and directly connected indeed, while the States’ practice reveals more graduated shadings: there is not always a relationship between a partial or total tax exemption and a relative or absolute immunity granted by host States. Further questions arise from subjective features: whether a tax exemption applies both to SWFs and to State-owned entities (SOEs) is still a disputed matter. In theory, host States should grant a tax exemption to SWFs more than to SOEs, as the former are State investors, and the latter are companies operating abroad and subject to host-State company law, regardless of their owner. On the contrary, the common practice is quite surprising. The practice adopted by States when it comes to the taxation of SWF investments may fall into one of the following three main groups. The first one consists of States whose national laws grant tax exemption to sovereign investments based on the accepted belief that they are implementing a general principle of international law: par in parem iudicium non habet. In this first group, tax exemption is seldom absolute, while more often it depends on the nature of the business. In the second group we find those States where limited or absolute tax exemption is granted under a bilateral investment treaty, usually on a reciprocity basis. The last group is that of States that do not grant any tax exemption to foreign investments, either relative or absolute, under any condition.
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Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.000 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it