This Handbook was developed as part of a project implemented jointly by the Financing for Development Office (FfDO) and the International Tax Compact (ITC). Its ten chapters were drafted by renowned international tax experts on the basis of the inputs provided by officials from national tax authorities in 35 developing countries, representing all regions of the world. Through a novel demand-driven approach, it 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, having regard to the specific needs and interests of these countries.
This United Nations Handbook on Administration of Double Tax Treaties for Developing Countries (the Handbook) is a result of a project, undertaken jointly by FfDO and ITC. The financial contribution for the project was provided by the German Federal Ministry for Economic Development and Cooperation.
The project was launched in December 2012. As the first step, two simultaneous technical meetings were held in Rome, Italy, on 28-29 January 2013, with the participation of 25 representatives of national tax authorities and ministries of finance from developing countries, representing all the regions of the world. The discussion on the administration of tax treaties, held within several thematic sessions, was facilitated by several members of the United Nations Committee of Experts on International Cooperation in Tax Matters (the Committee) and representatives of international and regional organizations. See report of the meeting for full record. It contributed to identifying the needs, skill gaps and challenges faced by developing countries in the area of tax treaty administration and taking stock of the available capacity development tools at their disposal.
Taking into account those findings, the national participants and other experts then agreed on “terms of reference” for a series of technical papers, which would address the specific issues in the administration of tax treaties of interest and concern to developing countries.
Accordingly, the draft papers were prepared by several international tax experts and underwent a peer review. These papers were then presented by the authors for discussion during a technical meeting, held in New York, on 30-31 May 2013, with the participation of 32 representatives of the national tax authorities and ministries of finance of developing countries. Each paper was discussed in a separate session, which was chaired by a member of the Committee or by a representative of an international or regional organization. Following a presentation by the author, a designated lead discussant representing a developing country was invited to comment on the paper, focusing on the specific experience of their country. This was followed by an open exchange of views among all the participants. During the discussion, there were many practical suggestions on how the papers would better meet the realities of developing countries’ tax administrations. The South-South sharing aspect emerged very prominently.
Following the meeting, the authors revised their papers taking into account feedback received from other experts. The papers were then finalized and edited to comprise the Handbook.
The Handbook was then launched and distributed at the OECD Meeting with non-OECD Economies and International Organizations preceding the 18th Annual Tax Treaty Meeting, which was held in Paris, in September 2013.