Direct taxation, tax treaties and IIAs

This chapter explores the relationship between international taxation and FDI, and the ways double taxation conventions (“tax treaties”) and IIAs address the rights and obligations of states, investors and taxpayers. We use the Canadian network of tax treaties and IIAs to illustrate the potential for interaction between the two types of agreements, as Canada has an interesting perspective as a jurisdiction that is both capital-importing and capital-exporting, and as a founding member of the OECD. Further, Canada has formulated a model FIPA ¹ and has a demonstrable policy of concluding tax treaties with its IIA partners. ²