Considers H.R. 5, the Foreign Investment Incentive Tax Act of 1959, to provide tax incentives to encourage capital investment and trade expansion with developing countries, especially by small businesses.

Tax incentives neither make up for serious deficiencies in a country's investment environment nor generate the desired externalities. But when other factors, such as infrastructure, transport costs, and political and economic stability are more or less equal, the taxes in one location may have a significant effect on investors' choices. This effect varies, however, depending on the tax instrument used, the characteristics of the multinational company, and the relationship between the tax systems of the home and recipient countries.

The purpose of this book is to provide within a single volume a comparative analysis of the tax laws of developed countries bearing upon direct private investment in developing countries, and a representative sample of developing country laws bearing upon the receipt of such investment. This study was initiated by the Tax Committee of the Business Section of the International Bar Association under the leadership of Jean-Claude Goldsmith of the Paris Bar. I undertook to act as the reporter, to browbeat colleagues in other countries to write national reports, and to provide the reporter's overview statement. This report includes studies of fourteen developed countries prepared by national reporters and summaries of five other developed country laws. Note worthy are the detailed examinations of the laws of the Federal Republic of Germany and of Japan, the two developed countries that have provided the most comprehensive system of incentives for private investment in developing countries. Also contained herein are reports from eight developing countries, including a thorough examination of the laws of Brazil. Attention is paid in the developed country reports not only to those tax provisions that act as in inducement to foreign investment but also to those that favor domestic investment and hence act as a disincentive to foreign investment. Relevant double taxation agreements are discussed, and other aspects such as exchange control and government grants are also mentioned.