Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries PDF full book. Access full book title Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries by United Nations. Department of International Economic and Social Affairs. Download full books in PDF and EPUB format.
Author: United Nations. Department of International Economic and Social Affairs
Publisher:
ISBN:
Category : Conflict of laws
Languages : en
Pages : 208
Get Book Here
Book Description
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.
Author: United Nations
Publisher:
ISBN: 9789211591101
Category : Political Science
Languages : en
Pages : 0
Get Book Here
Book Description
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:
Publisher:
ISBN:
Category :
Languages : en
Pages : 266
Get Book Here
Book Description
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.
Author: United Nations. Department of International Economic and Social Affairs
Publisher:
ISBN:
Category : Conflict of laws
Languages : en
Pages : 208
Get Book Here
Book Description
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.
Author: United Nations Publications
Publisher:
ISBN: 9789212591247
Category : Political Science
Languages : en
Pages : 286
Get Book Here
Book Description
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: United Nations. Department of Economic and Social Affairs
Publisher:
ISBN:
Category :
Languages : en
Pages : 222
Get Book Here
Book Description
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.
Author: Social Affairs
Publisher:
ISBN:
Category :
Languages : en
Pages : 190
Get Book Here
Book Description
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 190
Get Book Here
Book Description
Author: Alex P. Schmid
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 190
Get Book Here
Book Description
Author: UN. Department of Economic and Social Affairs. Division of Public Administration and Development Management
Publisher:
ISBN:
Category :
Languages : en
Pages : 256
Get Book Here
Book Description
Author: UN. Ad Hoc Group of Experts on International Cooperation in Tax Matters (10th : 2001 : Geneva)
Publisher:
ISBN:
Category :
Languages : en
Pages : 259
Get Book Here
Book Description
