Guidelines for Tax Treaties Between Developed and Developing Countries

Guidelines for Tax Treaties Between Developed and Developing Countries
Author: United Nations. Department of Economic and Social Affairs
Publisher: New York : United Nations
Total Pages: 80
Release: 1974
Genre: Double taxation
ISBN:

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.

United Nations Model Convention for Tax Treaties Between Developed and Developing Countries

United Nations Model Convention for Tax Treaties Between Developed and Developing Countries
Author: Stanley S. Surrey
Publisher:
Total Pages: 136
Release: 1980
Genre: Developing countries
ISBN:

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.

Taxation of Services in Treaties Between Developed and Developing Countries

Taxation of Services in Treaties Between Developed and Developing Countries
Author: Fernando Souza de Man
Publisher:
Total Pages: 370
Release: 2017
Genre: Taxation
ISBN: 9789087224219

The ease with which services are provided cross-border has increased considerably through the years, but this has not been reflected in the model conventions. Although this may not be an important issue when the flow of services between states is similar, it can have a huge impact on the collecting rights of states into which these services are mainly imported, such as developing countries. Nonetheless, developing countries? claims for more source taxation of services have been consistently neglected in model conventions.00With the intent of analysing whether the claims of developing countries are valid, as well as examining how the current system was structured, the author studies the legal and economic theories that support source and residence taxation and the historical documents concerning model conventions drafted by the League of Nations, the OECD and the United Nations. Furthermore, to better grasp the perspective of developing countries, the author analyses the situations of Brazil and India regarding the taxation of services in their domestic legislation and in their tax treaties, comparing the provisions of the latter with the current provisions in model tax conventions.

Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries

Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries
Author: United Nations Publications
Publisher:
Total Pages: 158
Release: 2014
Genre: Business & Economics
ISBN:

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.

Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries

Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries
Author: United Nations. Department of International Economic and Social Affairs
Publisher:
Total Pages: 208
Release: 1979
Genre: Conflict of laws
ISBN:

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.

Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries

Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries
Author:
Publisher:
Total Pages: 266
Release: 2003
Genre:
ISBN:

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.