IMF How To Notes

How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country

Author/Editor:

Kiyoshi Nakayama

Publication Date:

May 4, 2021

Electronic Access:

Free Download. Use the free Adobe Acrobat Reader to view this PDF file

Summary:

A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.

Series:

How-To Note No 2021/003

Subject:

Corporate income tax Dividend tax Double taxation Payroll tax Revenue administration Tax policy Taxes Withholding tax

Frequency:

occasional