Subcommittee on Review and adoption of the revised draft Manual for the
Negotiation of Bilateral Tax Treaties between Developed and Developing Countries

• Status: Active
• Coordinator: Mr. Ben Arrindell (Barbados)
• Members
  • Mr. Frank Brunetti (Fairleigh Dickinson University, USA)
  • Mr. Lara Yaffar (Mexico)
  • Ms. María Raquel Ayala (CIAT)
  • Mr. Tizhong Liao (China)
  • Ms. Rowena G. Bethel (Bahamas)
  • Mr. Wolfgang Lasars (Germany)
  • Mr. Ridha Hamzaoui (IBFD)
  • Mr. Tomas Balco, (KIMEP, Kazakhstan)
  • Mr. Bret Wells (University of Houston - Law Center, USA)
• Mandate

Based on the changes to the UN Model, prepare a shorter version of the Manual with practical example involving treaties between both developing and developed countries.

• Creation: First session of the Committee (November 2005)
• Activities:
  • Reports
    • Manual for the negotiation of tax treaties between developed and developing countries (2006)
      Contents Part 1 Part 2 Part 3 Annex
    • Revision of the UN Manual for the negotiation of tax treaties between developed and developing countries (2007)
    • Revision of the United Nations manual for the negotiation of bilateral tax treaties between developed and developing countries (2008)
      Note by the coordinator of the working group
      Addemdum: Article 5—Permanent Establishment
    • Revision of UN Treaty Negotiation Manual (Advance Unedited Version) ( 2009)
    • Draft Sections of the Manual (2010)
      Section 1: Basic Approaches
      Section 2: Appendix for Special Consideration Articles
    • Note on the Revision of the Manual for Negotiation of Bilateral Tax Treaties (2011)
      Introduction to International Double Taxation and Tax Evasion and Avoidance
      International Tax Evasion and Avoidance
      Suggestions Relating to the Application of the Articles of the UN Model Convention and Procedural Aspects of Tax Treaty Negotiations
      Basic Approaches to Tax Treaty Negotiation
      Dispute Resolution Mutual Agreement Procedure
      Appendix for Special Consideration Items
      International Tax Websites
      Questionnaire on the Manual for Negotiation of Bilateral Tax Treat
• Output: A final draft is expected by October 2012.