The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries seeks to provide practical guidance on all aspects of tax negotiation, including how to prepare for and conduct negotiations. Treaty negotiators in developing countries are encouraged to use this Manual in preparing for tax treaty negotiations in light of their country’s policy framework and the intended outcomes they wish to achieve. Although the Manual provides a description of the Articles of the UN Model and, where there are differences, of those of the OECD Model Tax Convention on Income and on Capital, it is not intended to replace the detailed Commentaries on these two models; these constitute the most authoritative sources on issues of interpretation of the UN and OECD models and should be consulted in parallel with the Manual.