A new dataset has been created to analyze tax treaties signed by developing countries in Africa and Asia. These treaties affect how these countries can tax foreign investors. The dataset shows that restrictions on withholding tax rates have increased since 1970, while the threshold for taxing foreign companies has decreased. OECD countries tend to impose more restrictions on developing countries' taxing rights, while non-OECD countries allow more flexibility. This research raises questions about the impact of tax treaties on investment and encourages further study in this area.