United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries

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Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively implement double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. Primary audiences are officials of national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.



Exchange of information

Exchange of tax information has become one of the most commonly discussed and promoted features of the international tax system. In recent years, the G20 has encouraged countries to pursue increased exchange of tax information and has directed international organizations to coordinate and facilitate this effort. In April 2013, the G20 welcomed the “progress made towards automatic exchange of information which is expected to be the standard and urged all jurisdictions to move towards exchanging information automatically with their treaty partners, as appropriate.” Similarly, in June 2013, the G8 issued a communiqué also advocating multilateral automatic exchange as a “new single global standard” and emphasizing that “[i]t is important that all jurisdictions, including developing countries, benefit from this new standard in information exchange.” In recognition of the constraints faced by developing countries, this communiqué called on the OECD “to work to ensure that the relevant systems and processes are as accessible as possible to enable all countries to implement this new standard.” Given the pervasive attention to information exchange this is no longer a topic of interest to a limited number of jurisdictions. All countries and their national level tax officials must have a solid understanding of the broad context of the information exchange discussion and practice, a working knowledge of the various mechanisms of information exchange, and an appreciation of the issues and concerns that may be of particular interest to developing countries. Moreover, developing countries need to consider what is necessary for them to comply with their obligation to exchange information, how exchange of information may be beneficial to their own jurisdictions, and what features of such an agreement are most critical for them.


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