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Sovereign Immunity and Tax Treaties: A Comparative Analysis of the Taxation of Sovereign Wealth Funds in Singapore, Malaysia, and Australia

“On almost every measure of investment, Asia stands out as the world leader. Consider Asia’s share of global fixed asset investment: in 2014, the region accounted for 45% of the global total. Or consider foreign direct investment: in 2014, Asia attracted 33% of the global total. Clearly, the region is an attractive place for the world’s companies to deploy their capital.” Asia’s phenomenal economic growth and development in recent decades has predominantly been a result of trade and investment. While trade is not insignificant, economic growth in Singapore and Malaysia is largely attributable to investment and education. Legal and regulatory requirements can impede cross-border investment. Chief among these is taxation, particularly the interaction of domestic tax rules with tax systems and practices in other countries. The reduction of tax barriers to cross-border trade and investment is one of the primary purposes of tax treaties.