In October 2011, the United Nations Committee of Experts on International Cooperation in Tax Matters (the Committee) adopted an updated version of the United Nations Model Double Taxation Convention between Developed and Developing Countries (United Nations Model Convention), which provides assistance to developing countries in the negotiation of modern bilateral double-tax treaties reflecting these countries’ current circumstances and policy priorities. Tax treaties play a key role in the context of international cooperation in tax matters. On the one hand, they encourage international investment by reducing or eliminating double taxation over cross-border income. On the other hand, they enhance cooperation among tax administrations, especially in tackling international tax evasion.
Many developing countries lack adequate understanding of the provisions of the United Nations Model Convention, especially of its 2011 version, as well as sufficient skills and experience to efficiently negotiate, interpret and administer tax treaties. This may result in difficult, time-consuming or even unsuccessful negotiation or application of tax treaties.
Accordingly, the first area of focus of the United Nations Capacity Development Programme on International Tax Cooperation, initiated in 2012, has been on strengthening the capacity of the representatives of national tax authorities and ministries of finance in developing countries to negotiate, administer and interpret double tax treaties, drawing on the 2011 United Nations Model Convention.
In order to contribute to this objective and to address the relevant knowledge and skills gaps, the Financing for Sustainable Development Office has developed a comprehensive set of capacity development materials and activities in this area.
The UN Course on Double Tax Treaties, complemented by the UN Primer on Double Tax Treaties is the most basic capacity development tool, which is intended for officials in national tax authorities and ministries of finance in developing countries with very limited or no knowledge of tax treaties. The programmes on negotiation and administration of tax treaties are more advanced and intended for more specialized officials in ministries of finance and national tax authorities in developing countries, who respectively deal with negotiation or application of tax treaties in their day-to-day activities.