Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities
Why negotiate tax treaties? / Ariane Pickering -- Tax treaty policy framework and country model / Ariane Pickering -- Preparation for tax treaty negotiations / Odd Hengsle -- Annex 1. Example of a comparison of draft country model treaties: Article 15 -- Annex 2. Example of a comparison of draft country model treaties How to conduct tax treaty negotiations / Odd Hengsle -- Annex 1. Example of agreed minutes of first-round negotiations -- Annex 2. Example of agreed minutes of second-round negotiations -- Post-negotiation activities / Odd Hengsle.

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