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UN-ITC Workshop on Administration of Tax Treaties and Addressing Base-Eroding Payments

  • Date: 1 - 3 December 2015
  • Location: Berlin

The Financing for Development Office (FfDO) of UN-DESA has organized, in cooperation with the International Tax Compact (ITC), a 3-day workshop on Administration of Tax Treaties and Addressing Base-Eroding Payments.

The workshop aimed to further disseminate the content of the UN Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries (Handbook), which 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.

The workshop also featured presentations of the draft UN Practical Portfolios on Taxation of Income from Services and on Base-Eroding Payments of Interest.

The Practical Portfolios provided participants with a framework for the analysis and assessment of the provisions of a country’s domestic law and tax treaties dealing with payments for services and interest, with a view to examining the relevant risks of tax base erosion and identifying the various options to counter these risks, as well as the administrative aspects following such changes in domestic legislation and tax treaty policy.

The workshop included practical case studies, country experiences as well as good practices. The discussions were led by world-renowned experts in the field of double tax treaties and participants actively engaged in South-South sharing of experiences, adding valuable contributions to the shaping of the Practical Portfolios.

The workshop featured the official launch of the French translation of the Handbook, which is now available in addition to the versions in English and Spanish.

  • Information
  • Participation
  • Day 1
  • Day 2
  • Day 3

Information

  • Tentative Programme (with links to presentations)
  • Information Note

Participation

  • List of participants
  • Biographies of presenters

Day 1

  • Introduction
  • Persons Entitled to Treaty Benefits
  • Case Study: Entitlement to Treaty Benefits
  • Application of Treaties to Residents
  • Application of tax treaties to nonresidents (business profits and services)

Day 2

  • Application of Treaties to Non-residents: Taxation of Capital Gains
  • Administration of tax treaties with respect to investment income
  • Treaty Abuse
  • Tools for Applying Tax Treaties: Exchange of Information
  • Tools for Applying Tax Treaties: Mutual Agreement Procedure
  • Tools for Applying Tax Treaties: Arbitration
  • Case Study: Exchange of Information
  • Case Study: Mutual Agreement Procedure/Arbitration

Day 3

  • United Nations Practical Portfolio: Protecting the Tax Base of Developing Countries against Base Erosion with respect to the Taxation of Income from Services
  • United Nations Practical Portfolio: Protecting the Tax Base of Developing Countries with respect to Base Eroding Payments of Interest

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