An overview of the issues involved in the application of double tax treaties

Over the last few decades, the number of bilateral tax treaties has increased dramatically. The United Nations Model Double Taxation Convention between Developed and Developing Countries (United Nations Model Convention) and the Organisation for Economic Co-operation and Development Model Tax Convention on Income and on Capital (OECD Model Convention) provide models for countries to use in negotiating the terms of their treaties and are regularly updated. The United Nations Model Convention was most recently revised in 2011 and the OECD Model Convention in 2010. Developing countries are increasingly entering into tax treaties with developed and other developing countries in order to facilitate crossborder trade and investment. Although there is a vast and growing body of literature dealing with the substantive provisions of tax treaties and the relationship between those provisions and the provisions of a country’s domestic law, relatively little information is available about the practical application of tax treaties.

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