This 5-day comprehensive training course provides tax treaty negotiators from developing countries with practical experience in tax treaty negotiations and exposes them to problems commonly experienced during negotiation, application and interpretation of tax treaties. The course is based on both the United Nations Model Double Taxation Convention between Developed and Developing Countries (United Nations Model Convention) and the OECD Model Tax Convention on Income and on Capital (OECD Model Convention) and conducted in the form of simulated tax treaty negotiation of all the provisions of a bilateral convention with respect to taxes on income and on capital between two fictitious countries (developed and developing). The negotiations are based on fictitious treaty models, recent treaties and descriptions of the tax legislation of the two countries.

Participants are divided into teams supported by experienced treaty negotiators who act as technical advi¬sors for the teams. Participants are asked to head the actual negotiations of each treaty provision and each participant has an opportunity to head the discussion on, at least, two or three treaty articles during the week.

The course is intended for developing country offi¬cials who are, or will be, involved in the negotiation of tax treaties for their country.

The next UN-OECD Practical Workshop on Negotiation of Tax Treaties will be held in Vienna, Austria, on 30 May – 3 June 2016.