Papers on selected topics in negotiation of tax treaties for developing countries

image of Papers on selected topics in negotiation of tax treaties for developing countries
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 negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.



Post-negotiation activities

This paper focuses on several matters that have to be dealt with after agreement is reached on all major issues concerning a proposed treaty. The first issue regards the drafting of the two Articles on Entry into force and Termination where several problems may be met. The paper then discusses how to proceed with the preparation of the treaty for signature, including its translation (if necessary), getting the authority to sign it and then the actual signing. Issues relating to the post-signing activities that are necessary to bring the treaty into force and the obligations to be met after it has entered into force are also discussed. However, questions regarding the fulfilment of obligations laid down in Articles 26 (Exchange of information) and Article 27 (Assistance in the collection of taxes) are not considered.


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