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United Nations Model Double Taxation Convention between Developed and Developing Countries

image of United Nations Model Double Taxation Convention between Developed and Developing Countries
This publication is designed especially for developing countries and countries with economies in transition. The revision updates the widely used 2001 version of the Model. It is important for countries that seek assistance in the negotiation and implementation of modern bilateral double tax treaties reflecting their current circumstances and policy priorities. The Model recognizes that to avoid double taxation of investment, the country where the investment takes place and country of the investor often share taxing rights. The Model helps to move forward in a way that preserves an appropriate share of taxing rights for developing countries. It also promotes cooperation to deal with tax avoidance and evasion. Primary audiences are policy makers, diplomats, the general public, media and universities.

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Special provisions

Article 24 of the United Nations Model Convention, except for reference to a different paragraph of Article 12 in paragraph 4, reproduces Article 24 of the OECD Model Convention. The general remarks from the OECD Commentary on Article 24 are as follows:

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