Subcommittee on Tax Treaty Negotiation

Subcommittee on Tax Treaty Negotiation

Established: 20 October 2017
Coordinators: Patricia Mongkhonvanit (Thailand)

Participants in the Subcommittee:

Margaret Moonga Chikuba (Zambia)
Marlene Patricia Nembhard-Parker (Jamaica)
Carlos E. Protto (Argentina)
Stephanie Lynn Smith (Canada)
Titia Stolte-Detring (Germany)


The Subcommittee is mandated to propose updates to the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries, based on the following principles:

  • That it reflects the current version of the UN Model Double Taxation Convention between Developed and Developing Countries and the relevant UN Commentaries as well as ongoing decisions of the Committee leading to changes in them;
  • That it pays special attention to the experience of developing countries and reflects their realities and needs at their relevant stages of capacity development;
  • That it draws upon and feeds into, as appropriate, the relevant work done in other fora, especially the work on the toolkit on tax treaty negotiation by the Platform for Collaboration on Tax.

The aim of the Subcommittee shall be to present to the Committee an update of the Manual for consideration with a view to adoption to in 2019. Updates on the progress of the work shall be provided to the Committee at each preceding session. The Subcommittee may request the secretariat to develop necessary inputs and provide necessary support within its resources.