Papers On Selected Topics In Negotiation Of Tax Treaties For Developing Countries

Author : United Nations Publications
Publisher : Unknown
Page : 158 pages
File Size : 48,7 Mb
Release : 2014
Category : Business & Economics
ISBN : UCBK:C113543837

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Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries by United Nations Publications Pdf

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.

Author : United Nations Department of Economic and Social Affairs
Publisher : United Nations
Page : 196 pages
File Size : 49,8 Mb
Release : 2016-06-24
Category : Political Science
ISBN : 9789210576369

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United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries by United Nations Department of Economic and Social Affairs Pdf

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.

Author : United Nations Publications
Publisher : Unknown
Page : 286 pages
File Size : 43,8 Mb
Release : 2019-07-26
Category : Political Science
ISBN : 9212591248

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United Nations Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries 2019 by United Nations Publications Pdf

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

Author : Department of Economic and Social Affairs
Publisher : United Nations
Page : 238 pages
File Size : 51,9 Mb
Release : 2019-06-28
Category : Law
ISBN : 9789210042734

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United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries 2019 by Department of Economic and Social Affairs Pdf

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.

Author : United Nations
Publisher : Unknown
Page : 0 pages
File Size : 53,6 Mb
Release : 2016
Category : Political Science
ISBN : 9211591104

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United Nations Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries by United Nations Pdf

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.

Author : Veronika Daurer
Publisher : Unknown
Page : 0 pages
File Size : 55,8 Mb
Release : 2014
Category : Double taxation
ISBN : 9041149821

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Tax Treaties and Developing Countries by Veronika Daurer Pdf

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.

Author : Kiyoshi Nakayama
Publisher : International Monetary Fund
Page : 27 pages
File Size : 54,8 Mb
Release : 2021-05-04
Category : Business & Economics
ISBN : 9781513577012

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How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country by Kiyoshi Nakayama Pdf

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.

Author : United Nations Department of Economic and Social Affairs
Publisher : United Nations
Page : 592 pages
File Size : 42,8 Mb
Release : 2015-12-15
Category : Political Science
ISBN : 9789210572361

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United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries by United Nations Department of Economic and Social Affairs Pdf

Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources. This publication analyses a number of topics which are of particular interest and relevance to developing countries in raising revenues and protecting the tax base. It aims at providing practical assistance to these countries in assessing and addressing the relevant issues in an effective way. Primary audiences are officials of national tax authorities and ministries of finance in developing countries, other professionals dealing with tax matters, the general public, media and universities.

Author : Alexander Trepelkov,Harry Tonino,Dominika Halka
Publisher : Unknown
Page : 0 pages
File Size : 53,9 Mb
Release : 2013
Category : Law
ISBN : 9211591058

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United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries by Alexander Trepelkov,Harry Tonino,Dominika Halka Pdf

"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.

Author : UN Group of Experts on Tax Treaties Between Developed and Developing Countries,United Nations. Department of Economic and Social Affairs
Publisher : New York : United Nations
Page : 76 pages
File Size : 40,6 Mb
Release : 1978
Category : Double taxation
ISBN : MINN:31951D037920470

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Tax Treaties Between Developed and Developing Countries by UN Group of Experts on Tax Treaties Between Developed and Developing Countries,United Nations. Department of Economic and Social Affairs Pdf

Author : Anonim
Publisher : IBFD
Page : 679 pages
File Size : 49,7 Mb
Release : 2010
Category : Double taxation
ISBN : 9789087221188

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Tax Treaties: Building Bridges between Law and Economics by Anonim Pdf

In this book experts from the field of economics take a different view of tax treaty issues than experts from the field of law. In order to encourage the much needed communication between these two groups, a cross-disciplinary conference was held to discuss selected tax treaty issues from both a legal and economic perspective. Twenty-five conference papers on eight topics were prepared by lawyers and economists. The papers on legal issues were presented and discussed by economists, and vice versa. The interdisciplinary focus of the conference not only allowed an exchange of knowledge between two groups who think differently about similar issues, but also made it possible to better grasp the impact of the thinking of one group on the areas of interest to the other group. The outcome of the conference is reflected in this book. By showing the legal and the economic approaches to an issue, this book improves the general understanding of the two disciplines and demonstrates how the decisions in one discipline may influence the other discipline and its concepts. Twenty-two contributions are included, written by the most distinguished academics, practitioners and representatives of several international tax administrations and both tax and economic institutions.

Author : United Nations. Department of Economic and Social Affairs
Publisher : New York : United Nations
Page : 180 pages
File Size : 43,6 Mb
Release : 1976
Category : Double taxation
ISBN : MINN:31951D03792024C

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Tax Treaties Between Developed and Developing Countries by United Nations. Department of Economic and Social Affairs Pdf

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.

Author : Stanley S. Surrey
Publisher : Unknown
Page : 136 pages
File Size : 44,9 Mb
Release : 1980
Category : Developing countries
ISBN : UOM:35112101127191

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United Nations Model Convention for Tax Treaties Between Developed and Developing Countries by Stanley S. Surrey Pdf

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.

Author : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 51,8 Mb
Release : 2007
Category : Double taxation
ISBN : 9789087220235

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International Tax Policy and Double Tax Treaties by Kevin Holmes Pdf

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.

Author : Anonim
Publisher : Unknown
Page : 12 pages
File Size : 44,7 Mb
Release : 1980
Category : Double taxation
ISBN : OCLC:960941551

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Tax Treaties Between Developed and Developing Countries by Anonim Pdf