“Administration of Tax Treaties and Addressing Base-Eroding Payments”
Berlin, Germany / 1–3 December 2015
The Financing for Development Office (FfDO) of UN-DESA and the ITC co-organised a 3-day workshop on “Administration of Tax Treaties and Addressing Base-Eroding Payments” with the participation of representatives from developing countries in Africa, Asia, Eastern Europe and Latin America.
Based on the positive feedback on the “UN Handbook on Selected Issues in Administration of Double Taxation Treaties for Developing Countries”, which is available in English, Spanish and French, the workshop had the objective to further disseminate the content of the UN Handbook.
During the first two days, participants were provided with an overview of the general issues covered by the handbook, such as persons entitled to treaty benefits, application of treaties to residents and non-residents, treaty abuse and tools for applying tax treaties.
The third day focused on selected chapters of the UN Handbook which are of particular interest to developing countries. This part of the workshop featured presentations of UN Practical Portfolios on the Taxation of Income from Services and on the Base-Eroding Payments of Interest. Both Practical Portfolios provide a framework for the analysis of the provisions of a country’s domestic law and tax treaties dealing with base-eroding payments. In addition to examining the relevant risks of base erosion, they identify the various options for changes in domestic legislation and tax treaty policy to counter base-eroding payments.
The workshop included practical case studies, country experiences as well as good practices. The discussions were led by world-renowned experts in the field of double tax treaties.
- Introduction – Brian Arnold, Hugh Ault (0.2 MB)
- Persons Entitled to Treaty Benefits – Peter Harris (0.6 MB)
- Case Study, Persons Entitled to Treaty Benefits – Peter Harris (0.1 MB)
- Application of Treaties to Residents – Hugh Ault (0.2 MB)
- Application of Treaties to Non-residents – Adolfo Jimenez (0.2 MB)
- Case Study, Taxation of Non-residents, Capital Gains – Diane Ring (0.1 MB)
- Taxation of Non-residents, Capital Gains – Diane Ring (0.3 MB)
- Taxation of Non-residents, Investment Income – Carlos Gutierrez (0.3 MB)
- Treaty Abuse – Jacques Sasseville (0.3 MB)
- Tools for Applying Tax Treaties, Exchange of Information – Diane Ring (0.3 MB)
- Tools for Applying Tax Treaties, Arbitration – Hugh Ault (0.2 MB)
- Tools for Applying Tax Treaties, Mutual Agreement Procedure – Hugh Ault (0.2 MB)
- Case Study, Exchange of Information – Diane Ring (0.1 MB)
- Case Study, Mutual Agreement Procedure Arbitration – Hugh Ault (0.1 MB)