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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
Keywords: Credit method, Dividends, Double Taxation Treaties, Exemption Method, Foreign
To study the effect of DTT on inflow of FDI from bilateral countries to Thailand.
between Thailand and its bilateral countries to see how they work.
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
To investigate existing DTT and the clauses which are deterrent MNEs’ FDI to invest
in Thailand.
Relief”.
Research Questions
1. How differences on concluding DTTs among ASEAN countries, S-S and N-S has
affected FDI?
4. Does the methods of eliminating double taxation under DTTs effect on inflow FDI from
taxation under DTTs between Thailand and respective countries which can make Thai
6. How does methods of eliminating double taxation lead Thailand to develop on its DTTs
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
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
Hypothesis 7 Finding effect of applying credit method with Thailand by developed countries
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
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
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
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
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
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
ESTIMATING CATEGORIES
The estimations will be clearly divided into three categories presenting from;
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
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
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.
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
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,
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.
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.
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
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
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
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
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
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,
TECHNIQUES
Countries?
Baker, Paul L. An Analysis of Double Taxation Propensity Score
Eric (2010)
Network
(2015)
Pfaffermayr, Investment
Michael;
Winner,
Hannes (2006)
Variables Impact
(+
positive,-
Negative,
0 No
Effect)
1 FDI Inflows FDI The natural log of amount of FDI Dependent
Product per
Capita
log
Openness
Growth
rate (Baht/US$)
and metals
by ICRG
From the objective on comparing the using of different methods on eliminating double
taxation to the movement of FDI from abroad will pilot the model of Steven P. Cassou (1997)
to apply in my study. Notwithstanding, the researcher will apply the idea of John H. Dunning
(1981) owning to the characteristics of data which will be used on testing are appropriate.
Steven P. Cassou takes logarithm to both dependent variable and explanatory variables.
The dependent variable is the FDI from abroad to GDP of domestic. In the part of explanatory
FDI = f (GDP per capita, Population, Exchange Rate, Inflation rate, Unemployment Rate,
taxation Treaties)
FDIi,t = b0 + b1,i DTTi,t + b2,i UNR i,t + b3,i GDPPC i,t + b4,i POP i,t + b5,i TOP i,t + b6,i GROWTH i,t +
b7,i INFi,t + b8,i ER i,t + b9,i NR i,t + b10,i INST i,t + b11,i NR i,t
The countries which are chosen to be proxies on testing hypotheses based on the choosing
of countries who have high direct investment in Thailand and have different conditions
Table: Developed countries who invest high FDI in Thailand and have DTTs with Thailand
(1970-2017)
Million)
Japan 64,724.37
Table: Developing countries who invest high FDI in Thailand and have DTTs with Thailand
(1970-2017)
Million)
Table: Countries who invest high FDI in Thailand and have no DTTs with Thailand (1970-
2017)
Countries Inward FDI to Thailand (US$
Million)
Table: ASEAN countries who invest FDI in Thailand and have DTTs with Thailand (1970-
2017)
Million)
Philippines 492.66
Table: ASEAN countries who invest FDI in Thailand and have no DTTs with Thailand (1970-
2017)
Million)
Brunei 293.37
Table: Developing countries who apply credit method with Thailand (1971-2018)
Million)
Singapore 42,848.37
Table: Developed countries who apply credit method with Thailand (1970-2017)
Million)
Million)
Taiwan 4,009
Table: Developed countries who apply exemption method with Thailand (1970-2017)
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
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
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
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
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.
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
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
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
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
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
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
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
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.
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
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
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
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
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
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
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
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
Infrastructure
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
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
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.
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
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
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.
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
Reverse Causality
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
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