Do Tax Treaties Embody the Application of Sovereign Immunity? – An Assessment with Regard to Sovereign Wealth Funds

Journal
International
Bulletin for International Taxation 2015 (Volume 69), No. 11
This article concludes that a consideration of tax treaties with regard to sovereign immunity reveals that such treaties do not embody the doctrine of sovereign immunity. Governments with sovereign wealth funds should, therefore, negotiate a specific article in their tax treaties to provide certainty of tax treatment.