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The growth of investment flows from developed to developing countries depends on the international investment climate. An important component of this climate is the prevention of double taxation, i.e. the imposition of similar taxes in two or more states on the same taxpayer. Bilateral tax treaties have eased this problem and in 1980 the United Nations published a model double taxation convention between developed and developing countries. This has now been revised to take account of the changes in the globalisation of trade and finance since 1980. Although it is based on the OECD Model Convention, there are differences as it gives more weight to the source principle as opposed to the residence principle.
Text of, and commentary on, the U.N. Model Double Taxation Convention.
Text of and commentaries on a model convention prepared under the auspices of the United Nations Ad Hoc Group of Experts on Tax Treaties between Developed and Developing Countries. The model consists of articles based on guidelines formulated by the Group at its various meetings and their commentaries expressed at those meetings together with commentaries, where appropriate, drawn from the OECD's 1977 Model Tax Convention.
The United Nations Model Double Taxation Convention between Developed and Developing Countries: 2017 Update is a publication geared towards the international community especially developing countries and countries with economies in transition. This new revision of the UN Model updates the widely used 2011 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, country where the investment takes place and country of the investor often share taxing rights. The Model helps to do it in a way that preserves an appropriate share of taxing rights to developing countries. The Model also promotes cooperation to deal with tax avoidance and evasion.
Revised version of the United Nations Model double taxation convention between developed and developing countries 2017, with commentary.
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.
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.