Download or read book Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries written by United Nations Publications and published by . This book was released on 2014 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book United Nations Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries written by United Nations and published by . This book was released on 2016 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries provides a guide to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.

Download or read book Tax Treaties and Developing Countries written by Veronika Daurer and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Countries eliminate the burden of double taxation for their taxpayers who engage in cross-border business activities by negotiating tax treaties with other countries. In the case of developing countries, tax treaties are often entered into with the additional purpose of attracting foreign investment as a path towards development. It is not clear, however, what role such agreements play in a countryand’s development efforts. This thoroughly researched book is the first to tackle this important issue in depth. Through an analysis of the tax treaty provisions of eleven East African nations, the author unveils the actual impact of the UN Model on the tax treaty network of the countries analysed as well as the and“real-worldand” relationship between tax treaties and development. All the crucial components necessary for understanding this relationship are examined, including the following: how the UN Model (designed for developing countries) deviates from the OECD Model; to what extent developing countries actually make use of the UN Model during treaty negotiations; the various functions of tax treaties, including elimination of double taxation, allocation of taxing rights, prevention of tax avoidance and fiscal evasion, and promotion of investment activities; the question of how source and residence taxation can be justified and which of these two concepts should be given preference; exchange of information issues; the problem of tax havens; the concept of transfer pricing; the concept of permanent establishment; patterns discerned in the treaty policy of developing countries and recurring non-model provisions; treatment of business profits, royalties, and capital gains; interest exemptions; technical and administrative fees and treatment of pensions and annuities. This book underscores the importance of tax treaties for developing countries. Its contribution to our understanding of both development and international taxation, and their reciprocal relationship, cannot be overemphasized. Further, it proposes modifications to the UN Model and its Commentary and suggests wording for additional provisions reflecting the tax treaty policy of the countries analysed in the book. The book will thus prove of immeasurable value to practitioners, academics, and policymakers in these disciplines.

Download or read book Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries 2019 written by United Nations. Department of Economic and Social Affairs and published by . This book was released on 2019 with total page 222 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Manual provides practical guidance on all aspects of tax treaty negotiation, including on how to prepare for and conduct negotiations. Section I of the Manual introduces the main principles which underlie double tax treaties, including the concepts of residence and source. It deals with methods for the elimination of double taxation, as well as the risks associated with the failure by the residence country to provide relief of double taxation, excessive source taxation, tax discrimination and uncertainty and complexity in the tax environment. In addition, it discusses how tax treaties may help in addressing tax avoidance and evasion and in preventing tax base erosion, including situations of double non-taxation. Section II of the Manual first addresses the fundamental question of why a country should negotiate tax treaties. It then elaborates on the importance of developing a tax treaty policy framework and a country model before entering into negotiations. It finally provides a comprehensive overview of the practical steps to be taken before, during and after the negotiation of each tax treaty. The core of the Manual is contained in Section III, which introduces the different provisions of the UN Model. It is not intended to replace the explanations provided in the Introduction and Commentaries on the Articles of the UN Model, but rather to provide a simple tool for familiarizing less experienced negotiators with these provisions. Chapter IV (Taxation of capital) briefly describes the provisions contained in Article 22 dealing with taxes on capital. Chapter V (Methods for the elimination of double taxation) illustrates the operation of Article 23, which requires the country of residence of the taxpayer to provide relief from double taxation. This may be done by either the exemption method or the credit method. Chapter VI (Special provisions) analyses Articles 24 to 29, which include the provisions dealing with non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, relationship with fiscal privileges of diplomats and entitlement to treaty benefits. Chapter VII (Final provisions) covers the procedures for the entry into force and termination of treaties, as included in Articles 30 and 31. Section IV of the Manual deals with the improper use of tax treaties, which may occur, for instance, when taxpayers enter into certain transactions or arrangements for the purpose of obtaining treaty benefits which would not otherwise be available to them. Section IV reviews the different tools that are available to prevent the granting of treaty benefits in these situations while taking into account the need to provide certainty and stability in the application of tax treaties.

Download or read book United Nations Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries 2019 written by United Nations Publications and published by . This book was released on 2019-07-26 with total page 286 pages. Available in PDF, EPUB and Kindle. Book excerpt: This manual provides insights to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.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

Download or read book Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries written by United Nations. Department of International Economic and Social Affairs and published by . This book was released on 1979 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book brings together the guidelines on issues relating to the negotiation of bilateral tax treaties formulated by the United Nations Ad Hoc Group of Experts on Tax Treaties between Developed and Developing Countries during their first seven meetings. The first part contains an analytical and historical review of international double taxation and tax evasion and avoidance. The annex to the Manual reproduces the texts of the following model tax treaties: League of Nations (Mexico and London Drafts), Andean countries, and OECD, as well as the Nordic Convention on administrative assistance in tax matters.

Download or read book How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country written by Kiyoshi Nakayama and published by International Monetary Fund. This book was released on 2021-05-04 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.

Download or read book Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries written by and published by . This book was released on 2003 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Manual provides a detailed introduction to the issues addressed in the United Nations Model Double Taxation Convention between Developed and Developing Countries as revised in 2001. The goal of the Manual is to assist developing countries and economies in transition to negotiate tax treaties among themselves and with developed countries. The first edition of this Manual was published in 1979, which will be of interest to those wishing to study more deeply the history of double taxation avoidance agreements. The Manual as revised consists of three parts. Part One contains an analytical and historical overview of international double taxation and tax avoidance and evasion. Part Two contains in consolidated form the guidelines formulated by the Group of Experts. Part Three contains suggestions relating to procedural aspects of tax treaty negotiations and to the application of the guidelines. The Annex to the Manual reproduces the texts of the following model treaties: (1) the Model Bilateral Convention for the Prevention of the Double Taxation of Income (Mexico Draft, 1943); (2) the Model Bilateral Convention for the Prevention of the Double Taxation of Income and Property (London Draft, 1946); (3) the Model Convention for the Avoidance of Double Taxation Between Member Countries and Other Countries Outside the Andean Sub-region (Andean Model); (4) the OECD Model Convention on Income and on Capital (OECD Model, 2000); (5) the Convention on Mutual Administrative Assistance in Tax Matters (OECD and Council of Europe, 1988); and (6) the United Nations Model in Practice.

Download or read book Tax Treaties Between Developed and Developing Countries written by UN Group of Experts on Tax Treaties Between Developed and Developing Countries and published by New York : United Nations. This book was released on 1978 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries written by Alexander Trepelkov and published by . This book was released on 2013 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The UN Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries was developed as part of a project implemented jointly by FfDO and the International Tax Compact. Its ten chapters were drafted by renowned international tax experts on the basis of the inputs provided by officials from national tax authorities in 35 developing countries, representing all regions of the world. Through a novel demand-driven approach, it provides practical guidance to developing countries to effectively implement double tax treaties, especially those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries, having regard to the specific needs and interests of these countries."--Publisher website.

Download or read book United Nations Model Convention for Tax Treaties Between Developed and Developing Countries written by Stanley S. Surrey and published by . This book was released on 1980 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 1967, the United Nations Group of Experts on Tax Treaties Between Developed and Developing Countries was established to facilitate the conclusion of tax treaties between developing and developes countries. This task was to be accomplished through the formation of guidelines for these treaties and recommendations for their implementation. This monograph describes the the work of this UN Group.

Download or read book Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by New York : United Nations. This book was released on 1976 with total page 180 pages. Available in PDF, EPUB and Kindle. Book excerpt: Part one : report of the Ad Hoc Group of Experts on tax treaties between developed and developing countries on its sixth meeting. Part two : issues relating to tax treaties between developed and developing countries : report of the Secretary-General to the Ad Hoc Group of Experts.

Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Download or read book Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by . This book was released on 1973 with total page 220 pages. Available in PDF, EPUB and Kindle. Book excerpt: Part one : report of the Ad Hoc Group of Experts on tax treaties between developed and developing countries on its fourth meeting. Part two : issues relating to tax treaties between developed and developing countries : report of the Secretary-General to the Ad Hoc Group of Experts.

Download or read book Guidelines for Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by New York : United Nations. This book was released on 1974 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains guidelines consolidated from the previous reports prepared by the Group of Experts on Tax Treaties between Developed and Developing Countries, and it is designed as a handbook to assist the negotiation and to facilitate the conclusion of tax treaties.

Download or read book The Effect of Treaties on Foreign Direct Investment written by Karl P Sauvant and published by Oxford University Press. This book was released on 2009-03-27 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.

Download or read book Commentary on the Manual for the Negotiation of Bilaterial Tax Treaties Between Developed and Developing Countries written by Frank L. Brunetti and published by . This book was released on 2003 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: