ELIMINATING DOUBLE TAXATION AND DEVELOPING DOUBLE TAXATION

TREATIES BETWEEN THAILAND AND BILATERALCOUNTRIES

ABSTRACT

The research empirically examines whether the difference of tax methods of “Double taxation

Relief” under Double Taxation Treaties (DTTs) has affect the case of dividends between

Thailand (as host country) and bilateral countries (as home countries) differently or it mark

Foreign Direct Investment (FDI) decisions from home countries. Especially, it is comparing

under tax credit and tax exemption method which is explored by FDI data; based on 9 sampling

bilateral countries that had been chosen by applying different method on eliminating double

taxation (credit method or exemption method) together with different styles of investment

(South to South, North to South or ASEAN countries to Thailand). It is concluded that Thailand

from 1970 to 2017 as an indicator observed the suitable method for DTTs and its affect to FDI

flow in Thailand. In order to analyze data with efficient result; questionnaire and in-depth

interview are used as main research instruments that helps in analyzing data as well as testing

the defined hypotheses.

Keywords: Credit method, Dividends, Double Taxation Treaties, Exemption Method, Foreign

Direct Investment, Multinational Enterprise

Objectives of the Research

The objectives of the research will be:

 To study the effect of DTT on inflow of FDI from bilateral countries to Thailand.

 To analyze the methods on eliminating international double taxation under DTTs

between Thailand and its bilateral countries to see how they work.

 To describe the methods of mitigating international double taxation in case of dividend

payment which consists of Credit Method and Exemption Method.

 To study the effect of DTT in mitigating international double taxation by different

methods that may affect the inflow of FDI from bilateral countries to Thailand.

 To examine the difference of concluding DTTs among S-S, N-S and ASEAN-Thailand

give different impacts on inflow FDI to Thailand.

 To investigate existing DTT and the clauses which are deterrent MNEs’ FDI to invest

in Thailand.

 To make a recommendation to TIRS to amend the relevant provisions in DTTs,

especially, in the section of dividend payment under article of “Double Taxation

Relief”.

Research Questions

The research will be based on following research questions:

1. How differences on concluding DTTs among ASEAN countries, S-S and N-S has

affected FDI?

2. How have the DTTs been identified on affecting FDI in Thailand?

3. How the methods of eliminating double taxation under DTTs works?

4. Does the methods of eliminating double taxation under DTTs effect on inflow FDI from

bilateral countries to Thailand?

 5. What are the similarities or dissimilarities on the methods of eliminating double

taxation under DTTs between Thailand and respective countries which can make Thai

tax better or lower than other nations?

6. How does methods of eliminating double taxation lead Thailand to develop on its DTTs

with respective countries to be a guideline to TIRS?

METHODOLOGY

Introduction

The aim of this thesis is to investigate the effect of DTT on FDI inflows to Thailand

(host country) from 9 selecting bilateral countries (home countries). The major aims is to

examine whether the methods on eliminating double taxation under DTT which Thailand has

been concluded with its bilateral countries in the matter of dividends really boosts investment.

Regarding to the previous studies, the researcher pulls out a list of hypotheses which will be

tested in this research as following.

The finding’s lists can be exploded as following;

Hypothesis 1 Finding effect of having DTT with Thailand by developing countries on inflow

FDI to Thailand

Hypothesis 2 Finding effect of having DTT with Thailand by developed countries on inflow

FDI to Thailand

Hypothesis 3 Finding effect of having DTT with Thailand by ASEAN countries on inflow FDI

to Thailand

Hypothesis 4 Finding effect of having no DTT with Thailand by country on inflow FDI to

Thailand

Hypothesis 5 Finding effect of having no DTT with Thailand by ASEAN countries on inflow

FDI to Thailand
Hypothesis 6 Finding effect of applying credit method with Thailand by developing countries

on inflow FDI to Thailand

Hypothesis 7 Finding effect of applying credit method with Thailand by developed countries

on inflow FDI to Thailand

Hypothesis 8 Finding effect of applying exemption method with Thailand by developing

countries on inflow FDI to Thailand

Hypothesis 9 Finding effect of applying exemption method with Thailand by developed

countries on inflow FDI to Thailand

RESEARCH METHOD

This research uses Mixed Methods from combining Qualitative Research and

Quantitative Research. The researches has adapting the data which firstly comes out from

investigation secondary data from existing literatures by using qualitative method. This can

help the researcher in deeper understanding to critical finding out core facts in conducting

variables which will be used for analysing by quantitative research as well as conducting

questionnaire (Creswell, 2009).

When it had collection of data by qualitative method already, afterward the researcher

will do analysing model equation by making it to be consistent with the testing of effective

DTT on affecting the increasing amount of FDI flow into Thailand. To create the suitable

structure for this research model equation, the researcher has reviewed thoroughly from the

previous documents that relates to the variables of my study to develop to be research

conceptual framework.

This study applies qualitative method to examine the impact of DTT in FDI inflow

to Thailand whether DTT gives negative, positive or no effect of this type of international

movement of capital by home countries to Thailand. The qualitative method will show the
essential role for aiding the researcher in clarifying understanding MNEs’ decision on moving

their capital in term of FDI. This research looks to their preferable on investment which may

present that are any reasons to invest their capital cause from demanding some benefit from

signing DTT with Thailand or not. Nevertheless, investigation of economic factors will be

carried in this research model equation to investigate the impact of them on FDI inflow to the

Thai. Therewith this study also carries out the questionnaire which the research will explain

deeper in the section of Research Design.

ECONOMETRIC GRAVITY MODEL

The empirical analysis in this research is through the gravity model. This research

assigns the econometric gravity model to determine the determinants of inward FDI into

Thailand. From the literature review section, you will see that the literatures in this research

field applied the different models to their studies. But the main purpose of this research is to

determine factors of FDI by using gravity model which the result from estimation based on

conducting hypothesises will present the variables of attracting inflow FDI to Thailand by other

bilateral countries’ MNEs between the period of 1970 to 2017.

The model that is used in study about this inward FDI to Thailand is Gravity Model

following the concept of Bevan and Estrin (2004) in applying to use with this research study.

At all events, the researcher adds more explanatory variables and dummy variable in the model.

Moreover, the Gravity model is received the development from Newton’s Law of Gravitation

for using in predicting the movement of investment data and the price of goods and services

which happen in the different places. Moreover, the gravity model is able to use for study about

trade and investment in the international level (Anderson, 1979).

 Gravity Model is one method which has high ascendant on analysing the interesting of

country which is source of investment from foreign investor or identifying the factors which

could be able to influence FDI to the host country. However, there are some researcher put

different variables on affecting inward FDI such as shipping cost or labour wage rate to test

their hypothesises about determinants of FDI (Stone and Jeon, 1999). Notwithstanding, the

factor which is possible to receive from using this gravity model is the flexibility and the ability

of development this research baseline model to answering another questions of future

researchers in this field on the issue of determinants of trade and FDI.

ESTIMATING CATEGORIES

The estimations will be clearly divided into three categories presenting from;

1. The estimation impact of DTT on FDI inflow to Thailand

2. The estimation impacts of credit method and exemption method on FDI inflow to

Thailand

3. The estimation impacts of developed countries which have DTTs with Thailand (N-S)

and developing countries which have DTTs with Thailand (S-S) on FDI INFLOW to

Thailand as well as focusing on the ASEAN countries which have DTTs which

Thailand.

In this research, the study in the details of DTT affecting FDI inflow to Thailand are

divided in to three parts that will be used in helping estimation in-depth of the potential DTT

aiding on higher FDI presented as following;

Category No. 1 will investigate the effect of entering DTTs with Thailand by other

countries. In this case, Thailand will act as the host country which other countries will stand

on the position of resident countries. The estimation of result will come from analyzing the

significant from model equation to comparing between the countries which have DTT with
Thailand and without DTT with Thailand that which one can effect on FDI inflow to Thailand

as well as analyzing how they affect.

Category No. 2, the researcher chooses to study the methods on mitigating double

taxation under DTT on passive income. The dividend is chosen in this category study based on

the reasons which the researcher already provided before. In the section of dividend income

article, each country may choose to apply different method in eliminating international double

taxation issue. Some may apply for credit method and some may apply for exemption method.

Thus, this category will study about how each method affect inflowing FDI to Thailand.

Category No. 3, beside from previous 2 categories, the study of signing DTT between

developing countries with Thailand and developed countries with Thailand looks very

interesting to find out about how they affect inflow of FDI. Regarding to previous literatures

that have been identified about some of different factors on choosing to apply bilateral

agreements of developing and developed countries in particular their different points of view

in applying DTT.

After these three categories are analyzed, it will be useful estimation which is kind of

perfect covering the sensitive components under DTT which may be cause of movement of

FDI flows. As a result, this may be losing things that other previous researches had not been

covered.

Panel Data Analysis

This research goes for panel data analysis. This is because in the research consists of

more than one unit and those units will be collected data in multiple time periods to find

estimated value. If you ask why Time Series Analysis or Cross-section Analysis is

inappropriate to use. This is because for Time Series Analysis, it has data for different time

periods but use to analyse for single unit. And Cross-section Analysis, it will have data from

different cross section only for one point of time. While the Panel Data Analysis is the
combination of Time Series Analysis and Cross-section Analysis whereat very suitable with

the data set that the researcher has. The reason is because the data elements in this research

consist of multiple units of countries which have been entered DTTs with Thailand and

multiple periods of time to predict estimation whether DTT is the determinant which can attract

FDI inflow to Thailand or not.

It can point that the Panel Data is just some kind of combination the way of Time Series

Analysis aspect and Cross-section Analysis aspect of their data. Hence, we have Panel Data

for analysis which the researcher got the data of different 9 countries signed DTTs and not

signed DTT with Thailand together with the countries which applied different method on

eliminating DTTs (credit method and exemption method) with Thailand as statistic data from

these variables that are FDI, GDP per capita, Population, Exchange Rate, Inflation rate,

Unemployment Rate, Economic Growth, Trade Openness, Natural Resource, Infrastructure,

Institutions and Double taxation Treaties of those countries with Thailand in the different time

period of data. This is the strong reason to support of applying Panel Data Analysis.

Balanced Panel Data

The way of analysis Balanced Panel and Unbalanced Panel are different. Therefore, the

researcher should exactly classify which one is proper to this study. It’s clear that the panel

data of my study is classified as balance panel because the researcher got the data from the 9

countries as cross section. These countries will be taken to analyse the data following the time

periods 1970s to 2017s that this study focuses without missing out one of those countries in

any point of time. If the researcher misses one of them in some period, thereby it is unbalanced

panel.

Natural log FDI inflow

Almost of researchers when they assigned natural log to certain variable that is for

having better model which help to reduce variance and skewness. In sometime, the data that is
used in analysis may be not able to make the normal distribution which the normal distribution

will help the statistical value from testing data based on this research study works well and

efficiently. Thence, it is very necessary to test the data of dependent variable for finding out

that it falls down as the condition of skewness or not before analysis and coming out with final

result. In this research, the FDI inflow into Thailand which acts as dependent variable in this

study model analysis show the positively skewed, thereby it leads to the process of

transformation to reduce skewness. Moreover, Vaus (2004) has been introduced the way to

solve the problem of positively skewed by taking natural log to keep skewed less than 2. This

is the main reason of taking natural log to FDI inflow.

FDI flow instead of FDI stock

The reason of choosing FDI flow in stead of FDI stock as dependent variable is because

the FDI flow is proper if the research trends to look at the data year by year for analysis. The

amount of FDI will be presented over the period of time that is every one year which meets the

objective of this research that the researcher would like to see changing of FDI inflow to

Thailand year by year. While the FDI stock will be present as total accumulation of value in

holding assets of FDI at the given point of time.

In addition, some of literatures which have been looked for the determinants of FDI

most often used the FDI flow by giving the reason to support that FDI flow is quite strong

evidence to present to the policy maker because it is able to show the clearly picture of

movement of capital. And this picture can help the policy maker to easier point out the effect

of DTT as determinant of FDI that it is worth or not to have additional cost to country from

entering DTT in exchange for money flowing. This situation is especially concerned in the

view of government of host country (Paul L. Baker, 2012).

Fixed Effect Model

 Base on the situation of this research, the appropriate model to use for testing panel

data which is collected regarding to research’s aims is Fixed Effect Model (FEM). The reason

that why the researcher applies to use FEM is from if the individual effect (εi) which is the

effect that fills for different individual variable correlates to independent variable, then, the

FEM will be applied. While if εi is not correlate with individual independent variable, the

Random Effect Model (REM) will be suggest.

Moreover, if the unit (N) of study has large in multiple time periods will lead to make

the result of using FEM and REM show distinctly difference of estimated value (in this study,

the time periods of collecting cover 1970s to 2017s). In this case, it has to consider N in this

research study that N is from random of samples or not. If not, it will be meant N is selecting

samples which is picked up respect to the research’s inference.

The research’s inference, here it means the 9 countries as N are not come from random

of samples but they are from the selection of researcher under condition that N is the unit of

country that Thailand have different conditions on entering DTTs. So, 9 selecting countries are

only available units that can use in this research and not come from random from large samples,

it is there for proper to assign FEM in testing.

Table: Model Specification from Selected Literatures

AUTHOR TITLE ESTIMATION

TECHNIQUES

Neumayer, Do Double Taxation Treaties Fixed-Effects Model

Eric (2006) Increase Foreign Direct (FEM) and Random-

Investment to Developing Effects Model (REM)

Countries?
Baker, Paul L. An Analysis of Double Taxation Propensity Score

(2012) Treaties and Their Effect on Estimation and Fixed-

Foreign Direct Investment Effects Model

Barthel, The Impact of Double Taxation Generalized Method of

Fabian; Busse, Treaties on Foreign Direct Moment Estimators

Matthias; Investment: Evidence From Large (GMM)

Neumayer, Dyadic Panel Data

Eric (2010)

Braun, The Effects of Double Tax Fixed-Effects Model

Julia;Fuentes, Treaties for Developing

Daniel (2016) Countries. A Case Study of

Austria’s Double Tax Treaty

Network

Murthy, K.V. The Impact of Bilateral Tax Fixed-Effects Model

Bhanu ; Treaties: A Multi-Country

Bhasin, Niti Analysis of FDI Inflows into India

(2015)

Blonigen, Do Bilateral Tax Treaties Promote Ordinary Least Squares

Bruce; Davies, Foreign Direct Investment? (OLS) and Fixed-Effects

Ronald (2002) Model

Blonigen, The Effects of Bilateral Tax Ordinary Least Squares

B.A.; Davies, Treaties on U.S. FDI Activity (OLS) and Fixed-Effects

R.B. (2004) Model

 Egger, Peter; The Impact of Endogenous Tax

Larch, Mario; Treaties on Foreign Tax

Pfaffermayr, Investment

Michael;

Winner,

Hannes (2006)

Table: Explanation of Explanatory Variables and Expecting Signs

No. Explanatory Abbreviation Explanation Expecting

Variables Impact

(+

positive,-

Negative,

0 No

Effect)
1 FDI Inflows FDI The natural log of amount of FDI Dependent

flows into Thailand Variable

2 Having DTT DTT The countries where conclude DTTs +

with Thailand with Thailand

3 Unemployment UNR Percentage of labour who are able to +

Rate work but they are unemployed

4 In Growth GDPPC The natural log of Growth Domestic +

Domestic Product per Capita

Product per

Capita

5 Population POP Population which is assigned natural +

log

6 Trade TOP The value of Trade to GDP +

Openness

7 Economic GROWTH The growth rate of each year +

Growth

8 Inflation Rate INF The rate of inflation for each year -

9 Exchange Rate ER Currency rate which is changes in real -

rate (Baht/US$)

10 Natural NR The percentage of merchandise +

Resources exports from raw material, fuel, ores

and metals

11 Infrastructure INST The number of telephone line per 100 +

people and natural log is assigned

 12 Institutions IST The scores of country which are given +

by ICRG

From the objective on comparing the using of different methods on eliminating double

taxation to the movement of FDI from abroad will pilot the model of Steven P. Cassou (1997)

to apply in my study. Notwithstanding, the researcher will apply the idea of John H. Dunning

(1981) owning to the characteristics of data which will be used on testing are appropriate.

Steven P. Cassou determines the model as following.

fi,t = i + xi,t  + ui,t

By i=1,…..,n and t=1,…..t
And fi,t is FDI from abroad
 is own individual effect
xi,t is explanatory variables
i is bilateral countries at n countries
t is time period
 is parameter which is assumed to be equal
across countries
ui,t is error

Steven P. Cassou takes logarithm to both dependent variable and explanatory variables.

The dependent variable is the FDI from abroad to GDP of domestic. In the part of explanatory

variables will be shown in the model below.

The model from my research can be exploded as following;

FDI = f [(Economic Fundamentals), (Other Variables), (Investment Treaties)]

FDI = f (GDP per capita, Population, Exchange Rate, Inflation rate, Unemployment Rate,

Economic Growth, Trade Openness, Natural Resource, Infrastructure, Institutions, Double

taxation Treaties)

FDIi,t = b0 + b1,i DTTi,t + b2,i UNR i,t + b3,i GDPPC i,t + b4,i POP i,t + b5,i TOP i,t + b6,i GROWTH i,t +
b7,i INFi,t + b8,i ER i,t + b9,i NR i,t + b10,i INST i,t + b11,i NR i,t

The countries which are chosen to be proxies on testing hypotheses based on the choosing

of countries who have high direct investment in Thailand and have different conditions

on applying DTTs as the finding’s lists have been mentioned;

Table: Developed countries who invest high FDI in Thailand and have DTTs with Thailand

(1970-2017)

Developed Countries Inward FDI to Thailand (US$

Million)

Japan 64,724.37

Table: Developing countries who invest high FDI in Thailand and have DTTs with Thailand

(1970-2017)

Developing Countries Inward FDI to Thailand (US$

Million)

South Korea 2,901.64

Table: Countries who invest high FDI in Thailand and have no DTTs with Thailand (1970-

2017)
 Countries Inward FDI to Thailand (US$

Million)

Cayman Islands 5,132.33

Table: ASEAN countries who invest FDI in Thailand and have DTTs with Thailand (1970-

2017)

ASEAN Countries Inward FDI to Thailand (US$

Million)

Philippines 492.66

Table: ASEAN countries who invest FDI in Thailand and have no DTTs with Thailand (1970-

2017)

ASEAN Countries Inward FDI to Thailand (US$

Million)

Brunei 293.37

Table: Developing countries who apply credit method with Thailand (1971-2018)

Developing countries Inward FDI to Thailand (US$

Million)

Singapore 42,848.37

Table: Developed countries who apply credit method with Thailand (1970-2017)

Developed Countries Inward FDI to Thailand (US$

Million)

Great Britain 6867.22

Table: Developing countries who apply exemption method with Thailand (1970-2017)

Developing Countries Inward FDI to Thailand (US$

Million)

Taiwan 4,009

Table: Developed countries who apply exemption method with Thailand (1970-2017)

Developed Countries Inward FDI to Thailand (US$

Million)

Sweden 1193.596

The study of James R. Hines Jr. (1998) has been identified the value of dummy variable

to be 1 if county has applying tax sparing with Thailand and to be 0 if country has no applying

tax sparing with Thailand. Thereby, the researcher applies this idea with my research by the

value of dummy variable will be 1 if county has DTT with Thailand and to be 0 if country has

no DTT with Thailand. Also, the value of dummy variable will be 1 if county has applying

credit method with Thailand and to be 0 if country has applying exemption method with

Thailand.

VARIABLES

DTT is use as an explanatory variable and FDI inflow is used as Dependent Variable.

Even in the research models in the past have some researchers include DTT as one of their

explanatory variable but their results still shown conflict of DTT on attracting FDI inflow

present both significant and not significant. Thus, they left the curious to find out an other

answer to help in supporting their studies which this study is willing to justified the argument

of them.
CONTROLLED VARIABLES

From related existing literature which has been emphasized on testing the determinants

of FDI as for International Monetary Fund (IMF) working paper on the topic of “The

Disappearing Tax Base: Is Foreign Direct Investment (FDI) Eroding Corporate Income

Taxes?” (Reint Gropp and Kristina Krostial, 2000) provided the proper model on analysing

determinants of outflow and inflow FDI. However, I will change some variables on this original

model to make it suitable to test the result based on my research aims. But for its

macroeconomic variables will be still kept in my research and added more to increase effective

of management analysing result. Theses macroeconomic variables will act as Controlled

Variables regarding to difference countries have different economic circumstances which can

give effect to the final result of my research. Therefore, to mitigate unwilling events happen to

the result, there is the need of controlled variables to control some factors that have possible to

affect the model by putting in the regression analysis.

DUMMY VARIABLES

In assigning Dummy Variables as the part in measuring the impact of DTT on FDI

inflow into Thailand, it is for using the result of use these variable on testing hypothesises to

obviously predict on whether should or should not entering into DTT by the reason of expecting

to achieve increasing of FDI flow into country. Regarding the review of existing literatures,

the researcher could find out that under DTT consists of different ways on mitigating

international double taxation. Also, there are different types of the countries which concluded

DTT together as for N-N, N-S and S-S. Moreover, I found out that some countries chose to

ignore entering into DTT by giving different reason that I have explained already in my

literature review section.

 Hence, using dummy variables look necessary to be included as for the countries which

use credit method will be mentioned as 1 and the countries which use exemption method on

mitigating double taxation problem with Thailand will be mentioned as 0 as the value of

dummy variable for analysis. Or the countries which concluded DTTs with Thailand will be

mentioned as 1 and the countries without DTT with Thailand will be mentioned as 0 as well as

if the investment type is N to S (Developed countries to Thailand) will be mentioned as 1 and

if the investment type is S to S (Developing countries to Thailand) will be mentioned as 0.

VARIABLES AND DATA SOURCES

The panel data used in this study is composed of numbers from 9 countries, which is

chosen based on the conditions set by the researcher to cover research analysis. The time period

of this study covers year 1970 to 2018 regarding some of the target countries, which has been

concluded DTT a long time ago. The sampling countries carried out the data from well-known

sources as official online statistic data, such as UNCTAD, the World Bank Report as well as

the report by the Bank of Thailand. The total amount of panel data consists of 108 sets, which

are suitable to guarantee the accuracy of the empirical result of this research.

5.1 Dependent Variables

The factors of FDI have been mentioned in various existing literatures, where each

study contains different variables. As for the study of Amal et al., (2010), it studies the factors

that affect FDI in Latin American countries between the years 1996–2008. They found that

FDI is positively correlated with economic stability, economic growth, trade openness and the

development of political institutions. Nevertheless, Ang (2007) studied the factors that

determine FDI in Malaysia between 1996–2005. This study shows that real GDP has a positive

impact on FDI. At the same time, GDP growth rates also have positive impacts on FDI flow.

For the flow of FDI in the matter of the financial system, infrastructure and level of trade

openness as explanatory variables can increase the inflow of FDI as well. In addition, the study
of Khrawish and Siam (2010) sheds light on the factors that determine FDI in Jordan, based on

macroeconomic data from 1997–2007. This study shows that FDI in Jordan is associated with

economic growth and economic stability as well as financial stability.

Nevertheless, there is a tendency in the study of FDI in Thailand and the relationship

between FDI and macroeconomic variables of Thailand, which are GDP, internal demand and

inflation by using the Granger causality test to examine the causal relationship between

variables between 1993–2004 (Jantarangs, 2004). The result shows that the increase in GDP

and private investment are the main factors that attract FDI, while FDI is not associated with

inflation. In addition, this study also found that the increase in the inflow of FDI does not affect

the increase in GDP and private investment, since the proportion of FDI to GDP and FDI to

private investment have small proportion. Notwithstanding, Nurudeen et al (2011) studied the

factors that determine FDI in Nigeria between 1970–2008. The study found that factors that

have a positive impact on the FDI, including the level of trade openness of country,

privatisation, the level of infrastructure development and that the value of the currency is

depreciated, while inflation does not affect FDI.

The differences of flowing FDI of the United States of America in Latin America and

Asia between the years 1979–2009 was analysed by Al Nasser (2007). The results of his study

showed that factors of host countries, such as market size, GDP growth rate, macroeconomic

stability, level of trade openness and infrastructure help contribute more FDI from USA to

different regions. In addition, the study found that Latin American countries attract more US

investors than Asia due to better development of education. Additionally, the study in the

matter of economic factors affecting FDI inflows in India, Indonesia and Pakistan during 1971–

2005 was carried out by Azam & Lukman (2010). The results showed that the main factors that

determine the inflow of FDI are external debt, the level of trade openness of country, market

size, domestic investment and transportation. In addition, this study suggests that these
countries should set appropriate policies to support FDI inflows, such as reducing loans from

foreign countries, building strong politics, and developing infrastructure.

Empirical studies by Cai (1999) on the determinants of outward FDI in China represents

factors, such as natural resources which are the main motivation for China’s outward FDI in

less developed countries. On the other hand, Blomkvist and Drogendijk (2013) stated that this

relationship is not significant. The study on the relationship between FDI and unemployment

was carried out by Billington (1999). Billington noted that the more labourers in the host

country will bring more FDI. In other words, increase in the unemployment rate is a proxy of

the readiness of labourers in the host country. Hence, high unemployment rates can attract more

FDI. Thus, foreign investors will have ability to take advantage of labour resources, which is

the main reason of driving high FDI flow into host countries. Friedman et al (1976) argue the

same point in their study. Moreover, FDI is mentioned in the matter of its relationship with

DTT in the study of Barthel, Busse, Krever and Neumayer (2010). This study put together a

larger data set than previous research with a long period on analysis. At the result, they found

out that there is a more significant relationship of DTTs on attracting FDI rather than the

relationship of other independent variables on FDI.

In this research, the inflow of FDI from sampling bilateral countries to Thailand is used

as the main measure. This research chooses to use FDI flow instead of FDI stock regarding

which there is more literature. The determinants of FDI flow are more relevant rather than FDI

stock. The natural log of FDI flow is used in this study to reduce the skewness of distribution

regarding the amounts of each variable, which have a big gap. The data of inflow FDI from

sampling bilateral countries to Thailand are from Bank of Thailand statistic report, World Bank

indicator report and UNCTAD. The data of FDI flow in this study is recorded in the US dollar

and the data used falls between 1970–2017. This is because the researcher can capture FDI

flows from the historical period till the present time that Thailand has been entering DTTs with
bilateral countries. Notwithstanding, there are other databases to collect FDI data, since the

researcher begins the period of study in 1970.

5.2 Explanatory Variables

Overall, this study relates to 12 explanatory variables, which are explanatory variables

i.e. credit method and exemption method under DTT between Thailand and bilateral

countries. Notwithstanding, the controlling effects of other explanatory variables correspond

to most of the literature in the matter of FDI flows regarding the model specified in the earlier

part. The variables in the part of general economic policy relates to the production factors, size

of market, the stability of macroeconomic, inflation exchange rate and quality of institutions

in the host countries. This research uses the database from UNCTAD statistic report, World

Bank report, Bank of Thailand and Thai Revenue Department as its main sources of

information. For the next sections, it will show the list of explanatory variables that are

involved in this study as well as the details of each variable.

Market Size

One of the main reasons for FDI in a market is to seek countries which can provide low

tax and non-tariff barriers that exist in host countries. This is because FDI has a need to avoid

the cost of high transaction. However, in general, FDI is used to access the host countries’

markets and achieve a good position in the host countries, especially in countries with good

opportunities for achieving future dynamic growth in the matter of market. The size and growth

of the host country plays an important role in determining the direction of FDI.

From the study of Chakrabarti (2001), the size of the market is identified as an

important factor, which is accepted widely to stimulate the flow of FDI. When pointing to the

importance of the market size as the basic factor on influencing FDI, we can see that it has a

long history on the articles of this research area. The market size hypothesis affecting the FDI

has been carried out by Balassa (1966), and this topic is developed by Scaperlanda and Mauer
(1969), the latter supporting the idea that “[a] large market size is needed for efficient use of

resources and the economies of scale”. When the market size grows, the values of FDI begin

to increase and further, the FDI expands the market size expansion. In addition, the examining

factors that determine US FDI in European Economic Community between the years 1958–

1968 was developed by Scaperlanda and Mauer (1969). Their result concludes that the size and

growth of the host country market plays an important role in decision-making regarding direct

investment of foreign investors. For the hypothesis of market size on FDI states, regarding to

economies of scale, that if a host country does not meet market requirements in terms of the

size which the home country requires for the effective use on production, FDI will not take

place.

In particular, this thesis will use the natural log of GDP per capita (GDPPC) and the

natural log of Population (POP) as proxies to measure the market size, which both do to value

the current size of the market. Moreover, there is the need of valuing the size of the potential

market, which is related to the economic growth rate. In theory, countries which have

fast-moving economic growth should be able to attract FDI more than countries with a

relatively slow-moving economic growth. This is because the faster growth of economy means

larger market sizes. The size of the market and growth will have a positive impact on FDI.

Lastly, these variables should represent a positive effect on regression.

Exchange Rate

The exchange rate is one of the factors which many studies include in their studies to

find the effect of it on affecting FDI. Many studies have been discovered that the exchange rate

has no effect on outward FDI of MNE (Buckley el at., 2007; Bhasin and Jain, 2013; Das, 2012).

This result complies with the study of Duanmu and Guney (2009) in which they found out that

the exchange rate of host country has no significance on outward FDI from India, while it does

outward FDI from China. This is because the outward FDI from China has the tendency to
invest in the host country, which has a currency depreciation because the Chinese MNE plays

more attention to the exchange rate determinant of the host country. Similar to the study of

Kueh et al (2009), this study considered the exchange rate in the viewpoint of the push factor,

which found out that the currency appreciation of Singapore is the push factor that helps

support Singapore’s MNE increase its outward FDI.

The impact of the exchange rate changes on FDI flows that can make investors receive

or lose from currency depreciation, depending on the time they invest and the currency that

they rely on. Currency depreciation can work as an incentive, which can be the motivation of

the investment from MNEs from the fact that their dollar investment is converted into the local

currency. On the other hand, Ancharaz (2003) mentions that currency depreciation can also

increase the cost of imported inputs and decrease the value of profit delivery in foreign

currencies. Since the currency of the country has the reduction of exchange rate, there is an

assumption that the inflow of FDI will increase. Hence, the expected sign of the relationship

of exchange rate affecting the FDI represents a negative sign.

Macroeconomic Stability

Inflation rate (INF) is used as a representative on the study of macroeconomic stability

in the host country. In any study, researchers identify that a stable inflation rate trends

encourage inward FDI to host country (Aijaz, Sissiqui & Aumeboonsuke, 2014). For low

inflation, it often represented economic stability in the host country. On the contrary, high

inflation shows the ability of the government and the central bank on creating balance for the

country’s budget and efficient implementation on monetary policy. Hence, low inflation

countries will be able to attract more foreign direct investment (Kinoshita and Campos, 2004).

Alshamsi, Hussin and Azam (2015) examine the effect of the inflation rate of the host country

affecting inward FDI between 1980–2013. They discovered that there is no significant
relationship between the inflation rate and its inward FDI from sampling the home country to

host country, similar to the study of Duanmu and Guney (2009) and Kolstad and Wiig (2012).

Unemployment Rate

The relationship between the FDI and labour market is an important topic in the

literature related to the study of FDI. Botric and Skuflic (2006) state that the stability of a

country’s economy can use the employment or unemployment as a proxy on determining it.

Many studies also mentioned that the unemployment rate (UER) can be reduced by the flowing

of FDI. However, the relationship of the unemployment rate and FDI has to be concerned based

on the economic structure of each country as well as the types of FDI and the period of time

that FDI has been done. Hence, there are some experts as Chard (2011) who bring out the result

that the country which has a higher employment rate can encourage more FDI.

On the other hand, Brozen (1958) explains that when the unemployment rate is too high

in a country, it may be recorded as losing on the controlling balance on macro economy in this

situation in the host country with a high unemployment rate and hence considered to be

unsuitable country for FDI. In my study, the percentage of labour who are able to work but are

unemployed is used as the measure of the unemployment rate to carry out the hypotheses.

Economic Growth

Empirical literatures, such as Jiménez (2011) and Al Nasser (2010) which study the

economic growth as incentives for direct FDI provide reasons that make foreign investors

increase their investment faster when the market of host country is growing. When the

economic growth rate is high, it means the country has an aggregate demand, which leads a

high chance of opening to make profit for the country that will encourage more incentives of

foreign investors on increasing the investment in country (Lim, 1983). If the rate of economic
growth is higher, it indicates that there is a chance on expanding the market size of the country

in the future (Zhang, 2001). Moreover, as the size of the potential market is related to the

economic growth rate, in theory, fast-growing economic countries will be able to encourage

more FDI when compared with slow-growing economic countries as faster growth of economy

can define greater potential in market size. However, FDI can also contribute to more economic

growth. This event will bring the endogenous issue as goods growing FDI in the country will

expand economic growth. To solve this issue, the researcher will use the delay data of economic

growth rate by 1 year as a proxy, when the expected sign is positive on affecting the inflow of

FDI to Thailand. The information about economic growth rate comes from the World

Development Indicator.

Trade Openness

Trade openness (TOP) is one of the factors that influence FDI. The level of trade

openness can be measured from the portion of total export and import to GDP. In consideration

of the degree of trade openness as the push factor can find different results from the literatures.

Das and Paul (2011) found out that the trade openness can aid to encourage higher outward

FDI of country. It means that if the country has widely opening trade with other countries or

having less controlling of investment and movement of capital, it will cause outward FDI in

positive direction. Additionally, having more trade openness in a country leads the domestic

entrepreneur to have a chance to learn and exchange knowledge with foreign entrepreneurs

who come to invest in the country. This also brings the incurring of collecting skill and business

knowledge from international business transactions, which can be advantageous and supportive

to the outflow of direct investment of domestic entrepreneur.

However, there are some study that give conflict results to Bas as for the study of Kueh

et al (2010) which studied the outflow FDI of Singapore and found out that there is a negative

relationship between trade openness and outflow FDI of Singapore. This researcher cited that
Singapore’s degree of trade openness is very high and has plentiful factors that can attract FDI

flows into Singapore. So, when Singapore has trade openness at a high degree, inward FDI to

Singapore would go high, which means that Singapore’s entrepreneurs have a willingness to

join in investment from MNEs rather than going to do direct investment abroad. Apart from

that, Bhasin and Jain (2013) found out that the degree of trade openness of home country has

no significant to outward FDI of country’s MNE.

In the case that the trade openness is considered as pull factor of host country to influent

investment from home country, there is the study carried out that MNE of home country has

tendency to make outward FDI if the host country has high degree of trade openness (Duanmu

and Guney, 2009). Wherewith the degree of trade openness can reflect the atmosphere of

investment which is friendly to the international business transaction in particular of

developing countries’ MNE. Due to this, MNEs may have less experience or knowledge about

doing international business, thereby this MNE will have the satisfaction to invest in the

country where has high degree of trade openness because there is no need to face with

complication and limitation of condition on operating business.

Natural Resource

Natural resource (NR) of host country is a pull factor to encourage outward FDI from

home country Buckley el al (2007), Duanmu and Guney (2009). In 2012, Beule and Bulcke

used the percentage of export mineral and metal of host country to be a proxy of study. Beule

and Bulcke (2012) found that outward FDI from China and India tend to directly invest in the

country which has plentiful natural resources. They also used the percentage of exporting

gasoline in study and found out that the result complies with the study of Dunning (1993).

Dunning mentions that MNE will invest in Resource Seeking, while the studies of Buckley et
al (2007) and Duanmu and Guney (2009) found that the natural resources of the host country

has no significance to be a factor on influencing FDI from China and India.

Sachs and Warner (1997) state that the measure to control the natural resources of a

country is the export of a country’s natural resources, which is measured as the percentage of

GDP. The exporting of natural resource using resources in this case of agriculture, minerals

and fuels which the data is obtained from the WDI database. Most FDI which flows to

developing countries is passed through the investment of natural resources. Hence, natural

resources in the host country are expected to encourage FDI.

Infrastructure

In the matter of infrastructure (INST), many researches carry out as determinant of

outward FDI and give different results. Nor Aznin Abu Bakar, Siti Hadijah Che Mat and

Mukaramah Harun (2012) test the impact of infrastructure as a pull factor by using the case of

Malaysia between 1970–2010. They come out with the result that infrastructure has a positive

impact on the inflow of FDI to Malaysia by the infrastructure, which they use from the real

government expenditure per real GDP. Quazi (2007) uses the case of selecting countries in

Latin America as host countries to estimate the impact of infrastructure, which acts as a pull

factor on the inflow of FDI of the selecting countries. Quazi (2007) uses the natural log of

mobile phone connections per capita as a proxy for the availability of infrastructure. As result,

this author finds that if the infrastructure is getting high, the return on investment from foreign

countries is going to be high.

In the subject of infrastructure as a push factor on influencing outward FDI of home

country, there are many literatures to support the negative relationship between infrastructure

of home country and its outward FDI. Rashmi Banga (2009) contributes the empirical results

about the determinants which are drivers outward FDI from Asian developing economies. Bang

uses transport and communication to real GDP as proxy of infrastructure of home country
between 1980–2002. Banga finds that poor availability of infrastructure of home country will

lead to drive home country to increase its outward FDI. On the contrary, the study of Bhanu

K.V Murthy (2015) carries the result that infrastructure has no significance with outward FDI

in the case of developing countries between 1990–2009. However, Bhanu uses Energy

Production, Telephone Lines, Electricity Production, Road Sector Energy Consumption and

Air Transport as proxies for infrastructure.

Institutions

The quality of institutions in the country is hard to look as only a single measure. So,

the proper way to show the quality of institutions is the relevant factors, which is about deciding

the location of FDI. However, there are authors who use different measures on identifying the

quality of institutions. For example, there are some authors mention political stability and rule

of law as the proxies on measuring quality of institutions. Nevertheless, there are some authors

measure the quality of institutions in the different way which the proxies of study are the host

country’s level of corruption and bureaucratic efficiency. For the proxies in the study of the

effect of institutions on FDI, this study uses the information from the International Country

Risk Guide (ICRG), which is provided by the Political Risk Services (PRS). The ICRG index

offers 22 variables in three main risks, which consists of finance, economy and politics. To

signify the protection of property and contract rights, which will deliver a better portrayal of

the quality of the institution and in accordance with the context of this study, my study will use

the combined score of the two elements which are related to DTTs, which are investment

profiles and laws and order elements to be involved in testing the hypothesis. The investment

profile index has the score rank from 0 (highest risk) to 12 (lowest risk), which are involved

for the ranking of score consisting of repatriating profit, delaying of paying profit and

practicality of contract. For law and order, it has ranking of score from 0 (highest risk) to 6

(lowest risk) (PRS Group, 2007). Hence, in may study, higher values of score represents strong
institutions. It is expected that host countries which has higher index scores will encourage

more FDI.

Double taxation Treaties

There are a few empirical studies which carry out the impact of DTT on FDI. Moreover,

there is still contradiction about the results in this research subject. Some articles represent the

negative impact of DTT on FDI and some represent positive impact of DTT on FDI. There is

the part in the study of Blonigen and Davies (2002) mention the results of the test in the matter

of impact of FDI by using ordinary least squares which they modified testing from the study

of Markusen and Maskus (2001). At the final stage, they found out that there is negative impact

of DTT on FDI which the sampling target on testing is developed countries as home country

and developing countries as host country between 1982–1992. In accordance with the study of

Egger et al (2006), they stated that there is significantly negative impact of DTT on FDI which

is analysed using the FDI flows from developed countries to developed countries between

1980–1999. Notwithstanding, there are some researches argue with these results that have been

mentioned before such as the study of Coupé, Orlova and Skiba (2009) found out no evidence

to present the impact of DTTs on FDI, which works with the example of OECD countries as

home country and economic transitioning countries as host country. However, Neumayer

(2007) who studied on the impact of DTTs on FDI in case of USA as home country and

developing country as host country as well as in the case of OECD countries as home country

and developing countries as host country, the author found out that there is significant positive

impact of DTT on FDI.

The impact of the methods of reliving double taxation, such as credit method and

exemption method on moving of capital among countries have been investigate in very few

literatures. For example, the study of Davies (2003) uses the sampling countries which look
symmetric to investigate the way of choosing the methods on eliminating double taxation under

the OECD Model Tax Conventions, which suggest on using the credit and exemption method

on relieving double tax burden. The finding shows that both countries choose to apply the credit

method. Notwithstanding, there is the study of Thomas Dickescheid (2004), in which the author

examines the effect of methods on relieving double taxation of two small countries which have

exchanging of FDI. The finding presents that the exemption method makes both countries

create the highest welfare, while the effect of tax export can create a weakness to their tax

exemption on foreign income if they choose to use high tax rate.

From above supporting on exploring the new knowledge for my study, the researcher

carries out the hypotheses to analyse the effect of DTT on influencing FDI as well as the

methods under DTT on influencing FDI to Thailand from its bilateral counties.

5.3 Dealing with Missing Data

Missing data is the case which can often face in almost researches. The researcher needs

to consider to the suitable pathway for managing with missing data. The method on

management of missing data have various choices on consideration to use them. If the

researcher chooses insufficient method to handle with missing data, it will make distortion of

analysis. At any rate, the study of Wood (2004) which has been published in journals, such as

BMJ, JAMA and Lancet finds that 89% of researches facing with the problem of missing data,

and only 21% of researches provide the management to missing data. From this result of

findings can present that the management of missing data is still neglected.

My research purpose is to make the result of analysis coming out with non-bias, thus

the carrying out of method on handling of missing data is explored. The appropriate method

which is proper to my research is “Listwise Data Deletion”. This method is easy because it is

not interested in the occurring of missing data and analyses only a part of the completing data.
This method is appropriate in the case of missing small set of data. Moreover, this method is

set as principle for management of missing data in general computer’s statistic programs.

In my study, there are some missing data especially the data from sampling bilateral

countries on such as FDI statistic data which is completely provided for some bilateral

countries only between 1970–2017. However, this research is expected to analyse the data of

sampling bilateral countries with a high FDI to Thailand. So, the researcher omits missing data

by choosing only bilateral countries for which statistic data is provided to complete the

analysis.

SUMMARY

Above is sum of variables that get involve in this research. In summary, the variables

which is used in the model specification are the natural logarithm of FDI flows into Thailand

by sampling bilateral countries and there are 11 explanatory variables are used in analysis.

Next, under 11 explanatory variables consist of dummy variables which are in the matter of

countries which conclude DTTs with Thailand and countries which have no DTT with Thailand

and in the matter of countries which apply credit method with Thailand and countries which

apply exemption method with Thailand. Most of my interest is dedicated to the estimation on

the effect from using different method on eliminating double taxation.

Reverse Causality

The issue of Recursive Model usually happens in one or another of Econometrics

Model, although the data may not clearly present the incurring of this issue. This could be

eligible my study in the case which FDI of MNEs from capital exporting country could be

cause of increasing number of DTTs. The reason may be from the government of capital

exporting country sees its MNEs having core investment with some recipient countries. So, the

government may want to enter DTTs with those recipient countries to gain some tax benefits
which are provided inside the DTT. As the result, this will lead to the occurring of Endogeneity

issue.

Thus, in order to avoid this issue, some existing literatures which studied in the

resemble field with my research as for the studies of Eric N. (2006) and Paul L. Baker (2012)

provide the same suggestion that the Reverse Causality could be solve by assigning

Instrumental Variable Regression. The use of Instrumental Variable Regression will be done

by lagging time of all explanatory variables by one year to evade coincidence of dependent

variable and explanatory variables that is easily cause of reverse causality issue. Finally, if this

regression could not fulfil to resolve this issue, the result from FEM is still to use when its

result presents at acceptable level and quite consistent.

REFERENCES

Adams, J., 2007. Research methods for graduate business and social science students. [e-

book] Los Angeles; London: Los Angeles; London : Response. Available through:

.https://www.sciencedirect.com/science/article/pii/S105905601500194X - bbb0245

A. Jiménez (2011). Political risk as a determinant of southern European FDI in

neighboring developing countries. Emerging Markets Finance and Trade, 47 (2011),

pp. 59-74

Amal, M. and Raboch, H. (2010) Determinants of the FDI from developing countries: A

panel data analysis, Paper presented at the Academy of International Business Annual

Conference, 24–28 June 2010, Rio de Janeiro, Brazil.

Ancharaz, V.D. 2003. The Determinants of Foreign Direct Investment in a Comparative

Perspective: Is there a Bias against Sub-Saharan Africa? Forthcoming in: University of

Mauritius Research Journal.

Anderson, J.E., 1979. A Theoretical Foundation for the Gravity Equation. The American

Economic Review, [e-journal] 69 (1), pp.106-116.

Ang, J.B., 2007. FINANCIAL DEEPENING AND ECONOMIC DEVELOPMENT IN

MALAYSIA. Economic Papers: A journal of applied economics and policy, [e-journal] 26

(3), pp.249-260. 10.1111/j.1759-3441.2007.tb00434.x.

Anthony E Scaperlanda and Laurence J Mauer (1969). The Determinants of U.S. Direct

Investment in the E.E.C. American Economic Review, 1969, vol. 59, issue 4, 558-68
Ahmad, N. and Xiao, W. (2013) End of double taxation: Is the policy better when

announced? Journal of Policy Modeling. 35(6) p928-942

Aijaz, H., Siddiqui, A., & Aumeboonsuke, V. (2014). ROLE OF INTEREST RATE IN

ATTRACTING THE FDI: STUDY ON ASEAN 5 ECONOMY. International Journal of

Technical Research, 2(3), 59–70.

Alfaro, L. (2003). Foreign direct investment and growth: Does the sector matter. Harvard

Business School, 1-31.

Al-Sadig, A. (2011). Do International Investment Agreements Promote Foreign Direct

Investment? International Journal of Trade and Global Markets, 4(1), pp.25-49.

Avery Jones, John F., and others, ‘Credit and Exemption under Tax Treaties in Cases of

Differing income Characterization’, ET, 1996, issue No. 4, pp. 118–146

Azam M, Lukman L (2010) Determinants of foreign direct investment in India, Indonesia

and Pakistan: a quantitative approach. J Manag Sci 4(1):31–43

Baker, P.L., 2014a. An Analysis of Double Taxation Treaties and their Effect on Foreign

Direct Investment. International Journal of the Economics of Business, [e-journal] 21 (3),

pp.341-377. 10.1080/13571516.2014.968454.

Bhasin, N., & Jain, V. (2013) Home Country Determinants of Outward FDI: A Study of

Select Asian Economies. Social Science Research Network Working Paper No. 2206789.

Balassa, B (1966), “Tariff Reductions and Trade in Manufactures among Industrial

Countries”, American Economic Review, 56(3), 466-473.

Banga, R. (2003). Impact of Government Policies and Investment Agreements on FDI

Inflows. New Delhi, Indian Council for Research on International Economic Relations: 47.
Banga, Rashmi (2009). Impact of Government Policies and Investment Agreements on FDI

Inflows‖, Indian Council for Research on International Economic Relations (ICRIER).

Baker, P. (2014) An Analysis of Double Taxation Treaties and their Effect on Foreign Direct

Investment. International Journal of the Economics of Business. 21(3) p341-377

Barthel, F. Busse, M. and Neumayer, E. (2010) The Impact of Double Taxation Treaties On

Foreign Direct Investment: Evidence From Large Dyadic Panel Data. Contemporary

Economic Policy. 28(3) p366-377

Braun, J. and Fuentes, D. (2016) The Effects of Double Tax Treaties For Developing

Countries. A Case Study of Austria's Double Tax Treaty Network. Public Finance &

Management. 16(4) p383-433

Bryman A, Bell E. (2007). Business Research Methods. 2nd ed. New York: Oxford

University Press;

Blomkvist, K. and Drogendijk, R. (2013) The Impact of Psychic Distance on Chinese

outward Foreign Direct Investments. Management International Review, 53, 659-686.

Blonigen, B. and Davies, R.B., 2002. Do Bilateral Tax Treaties Promote Foreign Direct

Investment?[e- ]. Cambridge, Mass., USA:.

Blonigen, B. A., and Davies, R. B. (2004). The effects of bilateral tax treaties on US FDI

activity. International Tax and Public Finance, 11(5), pp.601-622.

Blonigen, B. A., and Davies, R. B. (2005). Do bilateral tax treaties promote foreign direct

investment. Handbook of international trade, 2, pp.526-546.

Billington, N. (1999) The location of foreign direct investment: an empirical analysis.

Applied Economics 31: 65-76.

Bond, E. and L. Samuelson. (1989). “Strategic Behaviour and the Rules for International

Taxation of Capital,” The Economic Journal 99, 1099–1111.

Busse, M., Königer, J., and Nunnenkamp, P. (2010). FDI promotion through bilateral

investment treaties: more than a bit? Review of World Economics, 146(1), pp.147-177.

Berglund, Martin & Bexelius, Fredrik, ‘Sweden’ in Blanluet & Durand (general reporters),

Key Practical Issues to Eliminate Double Taxation of Business Income (2011), pp. 625–644

Bénassy-Quéré, A., Fontagné, L. and Lahrèche-Révil, A., 2005. How Does FDI React to

Corporate Taxation? International Tax and Public Finance, [e-journal] 12 (5), pp.583-603.

10.1007/s10797-005-2652-4.

Black, J., 2017. A dictionary of economics. [e-book] 5th ed. / John Black, Nigar Hashimzade,

Gareth Myles.. ed. Oxford: Oxford : Oxford University Press. Available through: .

Bevan, A.A. and Estrin, S. (2004) The Determinants of Foreign Direct Investment into

Europe Transition Economies. Journal of Comparative Economics, 32, 775-787.

Buckley, P. J. and M. Casson (2002). The future of the multinational enterprise. Houndmills,

Basingstoke, Hampshire ; New York, Palgrave Macmillan.

Bank of Thailand (2019). Statistics Report.

<https://www.bot.or.th/English/Statistics/Graph/Pages/CPI.aspx> accessed 30 January 2019

Botric, V. & Škuflic, L. (2006). Main Determinants of Foreign Direct Investment in the

Southeast European Countries. Transition Studies Review, 13, 359-377.

Brozen, Y. (1958). Means for Maintaining Economic Stability. Journal of Farm Economics,

40, 1069-1078.

Cassou, S.P., 1997. The link between tax rates and foreign direct investment. Applied

Economics, [e-journal] 29 (10), pp.1295-1301. 10.1080/00036849700000019.

Craigwell, R. (2006). Foreign Direct Investment and Employment in the English and Dutch-

Speaking Caribbean. Working Papers, Tripartite Caribbean Employment Forum 2006,

Barbados.

Christians, A. D. (2006). Tax Treaties for Investment and Aid to Sub-Saharan Africa: A Case

Study. Brooklyn Law Review, 71(2), pp.639-700.

Chakrabarti, A. (2001). "The Determinants of Foreign Direct Investment: Sensitivity

Analyses of Cross-country Regressions." Kyklos 54: 89-114.

Campos, N., 2003. Why Does Fdi Go Where it Goes? New Evidence From the Transition

Economies[e- ]. International Monetary Fund.03/228.

Cai, K.G. (1999) Outward Foreign Direct Investment: A Novel Dimension of China's

Integration into the Regional and Global Economy, The China Quarterly, n. 160, pp. 856-

880

Coupé, T., Orlova, I., and Skiba, A. (2008, January). The effect of tax and investment treaties

on bilateral FDI flows to transition countries. In 9th Annual Global Development

Conference, Brisbane (Vol. 29).

Covrig, G. (2011) Double Taxation Avoidance: A Factor of Economical Stability.

Economics, Management & Financial Markets. 6(2) p879-882

C. Rochananonda, Tax incentives and FDI in Thailand, in: Proceedings of the International

Symposium on FDI and Corporate Taxation: Experience of Asian Countries and Issues in the

Global Economy (unpublished results).

Chai-anant C. and Jantarangs U. (2004). BOT Symposium 2004

Thailand’s current account adjustment: Development and responses to economic tools. <

http://econ.tu.ac.th/class/archan/rangsun/ec%20460/ec%20460%20readings/thai%20economy
/macroeconomy/current%20account/thailand's%20current%20%20account%20adjustment.pd

f> accessed 17 September 2018

Creswell, J.W., 2007. Designing and conducting mixed methods research. [e-book] Thousand

Oaks, CA: Thousand Oaks, CA : SAGE. Available through: .

Creswell, J. (2009). Research design Qualitative, quantitative, and mixed methods

approaches (3rd ed.). Thousand Oaks, CA Sage.

Crotty, M. (1998). The Foundations of Social Research: Meaning and Perspective in the

Research Process. London: SAGE Publications Inc.

Desai, Mihir A. and Hines, James Rodger, Evaluating International Tax Reform (July 2003).

Harvard NOM Working Paper No. 03-48. Available at

SSRN: https://ssrn.com/abstract=425943 or http://dx.doi.org/10.2139/ssrn.425943

Dudas, D. (2011) Forms of Double Taxation. Agricultural Management. 13(3) p59-66

Das, A. and Paul, B.P., 2011. Openness and growth in emerging Asian economies: Evidence

from GMM estimations of a dynamic panel. Economics Bulletin, [e-journal] 31 (3), pp.2219-

2228.

Dunning, J. H. (1977). Trade, location of economic activity and the MNE: A search for an

eclectic approach. In The international allocation of economic activity (pp. 395-418).

Palgrave Macmillan, London.

Dunning, J. H. (1992). Multinational enterprises and the global economy. Wokingham,

England ; Reading, Mass., Addison-Wesley.

Dunning, J. H. (2002) Determinants of Foreign Direct Investment: Globalization Induced

Changes and the Role of FDI Policies. Volume, 17 DOI:

Dunning, J. H., R. v. Hoesel, et al. (1996). Explaining the 'new' wave of outward FDI from

developing countries: the case of Taiwan and Korea. Maastricht, MERIT (Maastricht

Economic Research Institute on Innovation and Technology): 26.

Dunning, J. H. and R. Narula (1996). Foreign Direct Investment and Governments: Catalysts

for Economic Restructuring. New York, Routledge.

Dagan, T. (2000). The Tax Treaties Myth. New York University Journal of International Law

and Politics, 32, pp.939-996.

Daniels, J. P., O’Brien, P., and von der Ruhr, M. B. (2015). Bilateral tax treaties and US

foreign direct investment financing modes. International Tax and Public Finance, 22, pp.999-

1027.

Daurer, V., and Krever, R. (2012). Choosing between the UN and OECD tax policy models:

An African case study. EUI Working Paper. [online] Available at:

http://cadmus.eui.eu/bitstream/handle/1814/24517/rscas_2012_60rev.pdf?sequence=3

[Accessed 29 May 2017].

Davies, R. David, Principles of International Double Taxation Relief, Sweet & Maxwell 1985

(abbrev. Davies, Principles of International Double Taxation Relief (1985))

Davies, R. B. (2003). Tax treaties, renegotiations, and foreign direct investment. Economic

Analysis and Policy, 33(2), pp.251-273.

Davies, R. B. (2004). Tax Treaties and Foreign Direct Investment: Potential versus

Performance. International Tax and Public Finance, 11, pp.775-802.

Dickescheid, T. (2004). Exemption vs. credit method in international double taxation

treaties. International Tax and Public Finance, 11(6), pp.721-739.

Duanmu, J. and Guney, Y., 2009. A Panel Data Analysis of Locational Determinants of

Chinese and Indian Outward Foreign Direct Investment. Journal of Asia Business Studies, [e-

journal] 3 (2), pp.1-15. 10.1108/15587890980001512.

Das, Ch. Khanindra. 2012. Home Country Determinants of Outward FDI from Developing

Economies. Working Paper. Chennai: Institute for Financial Management and Research.

Easson, A. (2000). Do we still need tax treaties? Bulletin for International Fiscal

Documentation, 54(12), pp.619-625.

De Beule F, Van Den Bulcke D (2012) The impact of the global economic crisis on foreign

direct investment. The case of China. In: Florence E, Defraigne P (eds) Towards a new

development paradigm in the twenty-first century. Routledge, London, pp 49–65

De Beule F, Van Den Bulcke D, Zhang H (2011) Chinese outward direct investment in

Europe and Belgium: characteristics and policy issues. In: Brennan L (ed) Emergence of

southern multinationals and their impact on Europe. Palgrave MacMillan, New York, pp

195–225

Egger, P., Larch, M., Pfaffermayr, M., and Winner, H. (2006). The impact of endogenous tax

treaties on foreign direct investment: theory and evidence. Canadian Journal of

Economics/Revue canadienne d'économique, 39(3), pp.901-931.

Elkins, Z., Guzman, A. T., and Simmons, B. A. (2006). Competing for capital: The diffusion

of bilateral investment treaties, 1960–2000. International Organization, 60(Fall), pp.811–846.

Elkins, Z., Guzman, A. T., and Simmons, B. A. (2006). Competing for capital: The diffusion

of bilateral investment treaties, 1960–2000. International Organization, 60(Fall), pp.811–846.

East Asian Executive (1997) New U.S.-Thai tax treaty. East Asian Executive Reports. 19(12)

p4
Engelen, Franciscus Antonius, Interpretation of Tax Treaties under Interna- tional Law, iBFD

Publications BV 2004 (abbrev. Engelen, Interpretation of Tax Treaties under International

Law (2004))

Friedman, M. 1976. Nobel lecture: Inflation and unemployment. Journal of Political

Economy 85: 451–472.

Fan, W. and Yan, Z., 2010. Factors affecting response rates of the web survey: A systematic

review. Computers in Human Behavior, [e-journal] 26 (2), pp.132-139.

10.1016/j.chb.2009.10.015.

Fendt J Kaminska-Labbĕ R and Sachs W (2008) Producing and socializing relevant

management knowledge: Re-turn to pragmatism. European Business Review 20(6): 471-491.

Gallagher, K. P., and Birch, M. B. L. (2006). Do investment agreements attract investment?

Evidence from Latin America. Journal of World Investment and Trade, 7(6), pp.961–974.

Guba, E. G. (Ed.). (1990). The paradigm dialog. New- bury Park, CA: Sage.

Guba, E. G., & Lincoln, Y. S. (1994). Competing paradigms in qualitative research. In N. K.

Denzin & Y. S. Lincoln (Eds.), Handbook of qualitative research (pp. 105-117). Thousand

Oaks, CA: Sage.

Grix, J., 2010. The foundations of research. [e-book] 2nd ed.. ed. Basingstoke: Basingstoke :

Palgrave Macmillan. Available through: .

Gropp, R. and Kostial, K., 2000. The disappearing tax base: is foreign direct investment

eroding corporate income taxes? : European Central Bank, September 2000.[e- ].

Harun, Mukaramah and Che Mat, Siti Hadijahand Abdul Jalil, Ahmad

Zafarullah (2012) Impact of foreign direct investment on income distribution in Malaysia:

Social accounting matrix framework. Global Review of Accounting and Finance, 3 (1).

pp. 32-42. ISSN 1838-1413

Hamada, K. (1966). “Strategic Aspects of Taxation on Foreign Investment Income,”

Quarterly Journal of Eco-

Hallward-Driemeier, M. (2003). Do bilateral investment treaties attract foreign direct

investment? Only a bit…and they could bite. World Bank Policy Research Working Paper

3121. [online] Available at: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=636541

[Accessed May 29 2017].

Herzer, D. 2012. “How Does Foreign Direct Investment Really Affect Developing Countries’

Growth?” Review of International Economics. 20 (2): 396–414.

Hilling, Maria, ‘Changes in the Application of Tax Treaties’, Intertax, 2011, issue 10, pp.

521–523

Iqbal, B. A. (2016). India as a Top Destination in FDI Inflows: Is It a Reality or a

Myth? Productivity, 57(3), pp.266-274.

Inflationtool (2019). Value of 1970 South Korean Won today. <

https://www.inflationtool.com/south-korean-won/1970-to-present-

value?fbclid=IwAR17Kf7hUtX_GNW-zcMpzf3q-Ej7qiiSovBV2Jl6rfBV-jlnqq0UP-uxJGA>

accessed 11 July 2019

Indexmundi (2019). Brunei Official Exchange Rate <

https://www.indexmundi.com/facts/brunei/indicator/PA.NUS.FCRF?fbclid=IwAR3uDSRQdI

G-qsIydYyVcJLptiTH91hviAoK6x3-_Q41rDU0Y1d1a1tRVNA> accessed 11 12 June 2019

Japan External Trade Organization (2019). Japanese Trade and Investment Statistics. <

https://www.jetro.go.jp/en/reports/statistics.html>. Accessed 10 June 2019

James R. Hines, Jr., 1998. ""Tax Sparing" and Direct Investment in Developing

Countries," NBER Working Papers 6728, National Bureau of Economic Research, Inc.

J Marksuen, K Maskus (2001). General-Equilibrium Approaches to the Multinational

Firm: A Review of the Theory and Evidence. NBER Working Paper, volume 8334

Jackson, S. L. (2011). Research Methods: A Modular Approach, 2nd ed. Belmont, CA:

Wadsworth.

Janeba, E. (1995). “Corporate Income Tax Competition, Double Taxation Treaties, and

Foreign Direct Investment,”

Journal of Public Economics 56, 311–325.

Jeon, B.N. and S.F. Stone (1999). Gravity-Model Specification for Foreign Di- rect

Investment: A case of the Asia-Pacific Economies. The Journal of Business and Economic

Studies. Vol. 5, No. 1, ISSN: 1063343X. Fairfield University.

Khrawish, H.A. and Siam, W.Z., 2010. Determinants of direct foreign investment: evidence

from Jordan. Business and Economic Horizons, [e-journal] 1 (1), pp.67.

Kueh, J.S.H., Puah, C.H. and Liew, K.S. (2010). Selected Macroeconomic Determinants of

Foreign Direct Investment Outflow of Singapore. MPRA Paper No.25940.

K.H. ZhangWhat explains the boom of foreign direct investment in China?

The International Economy, 54 (2001), pp. 251-274

Kim, S. (2007). Bilateral investment treaties, political risk and foreign direct investment. Asia

Pacific Journal of Economics and Business, 11(1), pp.6-24.

Khamis, H.A., Mohd Rasid, B.H. and Azam, M., 2015. The impact of inflation and GDP per

capita on foreign direct investment: the case of United Arab Emirates. Investment

Management & Financial Innovations, [e-journal] 12 (3), pp.132-141.

Kolstad, I. and Wiig, A., 2012. What determines Chinese outward FDI? Journal of World

Business, [e-journal] 47 (1), pp.26. 10.1016/j.jwb.2010.10.017.

Lennard, M. (2009). The UN Model Tax Convention as Compared with the OECD Model

Tax Convention–Current Points of Difference and Recent Developments. Asia-Pacific Tax

Bulletin [online] Available at:

http://www.taxjustice.net/cms/upload/pdf/Lennard_0902_UN_Vs_OECD.pdf [Accessed 29

May 2017].

L. Alfaro, A. Chanda, S. Kalemli-Ozcan, S. SayekFDI and economic growth: the role of local

financial markets J. Int. Econ., 64 (1) (2004), pp. 89-112

D. Lim (1983). Fiscal incentives and direct foreign investment in less developed countries.

Journal of Development Studies, 19 (1983), pp. 207-212

Li, N. and Chen, Y. (2010). Elimination of International Double Taxation in Connection with

the Adjustment of Transfer Pricing. [online] Available at:

http://ieeexplore.ieee.org/document/5588909/?reload=true [Accessed 29 May 2017].

Matías-Guiu, J., Serrano-Castro, P., Mauri-Llerda, J., Hernández-Ramos, F.J., Sánchez-

Alvarez, J.C. and Sanz, M., 2014. Analysis of Factors Influencing Telephone Call Response

Rate in an Epidemiological Study. The Scientific World Journal, [e-journal] 2014

10.1155/2014/179375.
Miller, A., 2016. Principles of international taxation. [e-book] Fifth edition.. ed. Haywards

Heath, West Sussex : Bloomsbury Professional. Available through: .

Marques, M., and Pinho, C. (2014). Tax-Treaty Effects on foreign investment: Evidence from

European multinationals. FinanzArchiv: Public Finance Analysis, 70(4), pp.527-555.

Millimet, D. L., and Kumas, A. (2009). It's All in the Timing: Assessing the Impact of

Bilateral Tax Treaties on US FDI Activity. [online] Available at:

https://works.bepress.com/millimet/55/ [Accessed 29 May 2017].

Murthy, K. V., and Bhasin, N. (2013). The impact of bilateral tax treaties on FDI Inflows:

The Case of India. [online] Available at:

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2234966 [Accessed 29 May 2017].

Murthy, K.V.B. and Bhasin, N., 2015. The impact of bilateral tax treaties: A multi-country

analysis of FDI inflows into India. The Journal of International Trade & Economic

Development, [e-journal] 24 (6), pp.751-766. 10.1080/09638199.2014.960442.

Musgrave, P. (1969). United States Taxation of Foreign Investment Income: Issues and

Arguments. Cambridge, MA: International Tax Program, Harvard Law School.

N. Bhasin, V. Jain (2013). Home country determinants of outward FDI: A study of select

Asian economies. Social Science Research Network Working Paper No. 2206789 Social

Science Research Network Working Paper No. 2206789

Nurudeen, A., Wafure, O. and Auta, E., 2011. Determinants of foreign direct investment: the

case of Nigeria. IUP journal of monetary economics, [e-journal] 9 (3), pp.50-67.

Neumayer, Eric. 2006. Self-interest, Foreign Need and Good Governance: Are Bilateral

Investment Treaty Programs Similar to Aid Allocation? Foreign Policy Analysis 2 (3):245-

67.
Neumayer, E. (2007). Do double taxation treaties increase foreign direct investment to

developing countries? The Journal of Development Studies, 43(8), pp.1501-1519.

Neumayer, E., and Spess, L. (2005). Do bilateral investment treaties increase foreign direct

investment to developing countries? World Development, 33(10), pp.1567–1585.

Nepelski, D., and G. De Prato. 2015. “International Technology Sourcing between a

Developing Country and the Rest of the World. A Case Study of China.” Technovation 35:

12–21.

Nunnenkamp, P. (2002). Determinants of Foreign Direct Investment in Developing

Countries: Has Globalization Changed the Rules of the Game (Vol.11, pp.1-34). Kiel

Institute for the World Economy

OECD. (1997). OECD Model Tax Convention on Income and On Capital. Paris: OECD

Committee on Fiscal Affairs.

Ohno, T. (2010). Empirical analysis of international tax treaties and foreign direct

investment. Public Policy Review, 6(2), pp.287-312.

Omar M. Al Nasser, 2007. "The Determinants of the U.S. Foreign Direct Investment: Does

the Region Matter?,"Global Economic R3eview, Taylor & Francis Journals, vol. 36(1), pages

37-51.

O.M. Al Nasser (2010). How does foreign direct investment affect economic growth? The

role of local conditions. Latin American Business Review, 11 (2010), pp. 111-139

Parikh, B. R., Pankaj, J., and Spahr, R. W. (2011). The impact of double taxation treaties on

cross border equity flows, valuations and cost of capital. [online] Available at:
http://www.efmaefm.org/0EFMAMEETINGS/EFMA%20ANNUAL%20MEETINGS/2011-

Braga/papers/0250.pdf [Accessed 29 May 2017].

PACIFIC Exchange Rate Service (2019). Foreign Currency Units per 1 U.S. Dollar, 1950-

2018< http://fx.sauder.ubc.ca>accessed 11 July 2019

Quazi, R. M. (2007). Investment Climate and Foreign Direct Investment study of selected

countries in Latin

America. Global Journal of Business Research, 1(2), 1-13

Richman (later Musgrave), Peggy B., Taxation of Foreign Investment Income: An Economic

Analysis, John Hopkins Press 1963 (abbrev. Richman (later Musgrave), Taxation of Foreign

Investment Income (1963))

Sachs, J. D. and Warner, A. M. (1997a) “Sources of slow growth in African

economies,” Journal of African Economies 6(3): 335–376.

Sachs, J. D. and Warner, A. M. (1997b) Natural resource abundance and economic growth,

Center for International Development and Harvard Institute for International Development,

November.

Sachs, J. D. and Warner, A. M. (1997c) “Fundamental sources of long-run

growth,” American Economic Review 87(2): 184–188.

Saunders, M., Lewis, P. and Thornhill, A. (2007) Research Methods for Business Students.

4th Edition, Financial Times Prentice Hall, Edinburgh Gate, Harlow.

Stockmann, Frank, ‘Should the Exemption Method Have Priority over the Credit Method in

international Tax Law?’, BIFD, 1995, pp. 285–288 Sundgren, Peter, ‘Double tax conventions

and double non-taxation’, Webb- journal on international taxation, No. 2/2005,

<http://www.skatter.se/index.php?q=node/140> accessed 11 January 2012

Shah, M. H., and Qayyum, S. (2015). Impact of double taxation treaties on inward FDI in

Latin American and Caribbean developing countries. Business and Economic Review, 7(1),

pp.1-18.

Sharkey, N. C., and Bain, K. (2011). An Australia-Hong Kong double tax agreement:

Assessing the costs and benefits. eJournal of Tax Research, 9(3), pp.268-293.

Steenkamp, L. A. (2013). Beneficial ownership provisions in tax treaties between developed

and developing countries: the Canada/South Africa example. The International Business and

Economics Research Journal, 12(9), pp.1107-1118.

Steenkamp, L. A. (2014). The Permanent Establishment Concept In Double Tax Agreements

Between Developed And Developing Countries: Canada/South Africa As A Case In

Point. The International Business and Economics Research Journal (Online), 13(3), p.539.

Steenkamp, L. A. (2014). The Permanent Establishment Concept In Double Tax Agreements

Between Developed And Developing Countries: Canada/South Africa As A Case In

Point. The International Business and Economics Research Journal, 13(3), pp.539-553.

Suvarnapunya, C. and Chitranukroh, A. (2011) Tax planning challenges in Thailand.

International Tax Review. 22(8) p29

Sutana Thanyakhan (2008). THE DETERMINANTS OF FDI AND FPI IN THAILAND: A

GRAVITY MODEL ANALYSIS. < https://core.ac.uk/download/pdf/35459052.pdf>

Suzuki, M., 2014. The Effects of Repatriation Taxes on FDI:Evidence from OECD

Multinationals[e- ]. Kyoto University, Institute of Economic Research.902.

Tobin, J. L., and Rose-Ackerman, S. (2011). When BITs have some bite: The political-

economic environment for bilateral investment treaties. The Review of International

Organizations, 6(1), pp.1-32.

Tobin, J., and Rose-Ackerman, S. (2005). Foreign direct investment and the business

environment in developing countries: The impact of bilateral investment treaties. Yale Law

and Economics Research Paper No. 293. [online] Available at:

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=557121 [Accessed 29 May 2017].

The PRS Group (2019). International Country Risk Guide (ICRG).<

https://www.prsgroup.com/explore-our-products/international-country-risk-guide/>

Accessed 27 May 2019

The Revenue Department (2019). Double Taxation Agreements. <

http://www.rd.go.th/publish/766.0.html> Accessed 12 May 2019

UNCTAD (2000). Tax Incentives and Foreign Direct Investment. Geneva, United Nations.

UNCTAD. (2019). World Investment Report 2004. Message posted to

www.unctad.org/fdistatistics

UNCTAD. 1999. World Investment Report, New York: United Nations.

UNCTAD (2019). UNCTAD Statistics Report. <

https://unctadstat.unctad.org/wds/TableViewer/tableView.aspx> accessed 11 12 June 2019

United Nations. (1980). U.N. Model Double Taxation Convention between Developed and

Developing Countries. NY: U.N. Document No. ST/ESA/102.

Vandevelde, K. J. (1998). Investment liberalization and economic development: The role of

bilateral investment treaties. Columbia Journal of Transnational Law, 36, pp.501–527.

Vanderbruggen, E. and Win, T. (2012) Myanmar: New double taxation agreement between

Myanmar and Thailand. International Tax Review. 23(9) p54

World Bank (2019). World development indicators. Washington, D.C., The World Bank: v.

World Bank (2019). World Development Indicators. Washington, DC: World Bank, 1960-

2018.

World Bank (2018). Thailand Economic Monitor. December 2018.

Wood, A.M., White, I.R. and Thompson, S.G., 2004. Are missing outcome data adequately

handled? A review of published randomized controlled trials in major medical

journals. Clinical Trials, [e-journal] 1 (4), pp.368-376. 10.1191/1740774504cn032oa.

Yew, S. Y., Yong, C. C., and Tan, H. B. (2010). Impact of economic integration on foreign

direct investment into ASEAN5. Malaysian Journal of Economic Studies, 47(1), pp.73-90.

Ahmad, N. and Xiao, W. (2013) End of double taxation: Is the policy better when

announced? Journal of Policy Modeling. 35(6) p928-942

Zakus, D.H., Malloy, D.C. and Edwards, A., 2007. Critical and Ethical Thinking in Sport

Management: Philosophical Rationales and Examples of Methods. Sport Management

Review, [e-journal] 10 (2), pp.133-158. 10.1016/S1441-3523(07)70008-6.