United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries

The United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (2019) is a compact training tool for beginners with limited experience in tax treaty negotiation. It seeks to provide practical guidance to tax treaty negotiators in developing countries, in particular those who negotiate based on the United Nations Model Double Taxation Convention between Developed and Developing Countries. It deals with all the basic aspects of tax treaty negotiation and it is focused on the realities and stages of capacity development of developing countries.

While every country should form its own policy considerations and define its objectives in relation to tax treaties, this Manual seeks to provide practical guidance on all aspects of tax treaty negotiation, including on how to prepare for and conduct negotiations. Treaty negotiators in developing countries, especially those with limited experience, are therefore encouraged to use this Manual in preparing for tax treaty negotiations, in the light of their country’s policy framework and the intended outcomes they wish to achieve.