Tax Treaties between Developed and Less Developed Countries (1.5)
Gustafson, Charles, F 14/15, P 13/15
Bilateral tax treaties between industrialized countries arise in a context where the flow of investment and trade creates issues common to the tax policies of both treaty countries. Treaties between industrialized and developing countries, however, are negotiated in a sometimes dramatically different context because of the disparity in the flow of investment and trade and, therefore, income potentially subject to income taxation. This lecture will focus on the way in which such differences are reflected in model treaties developed by international organizations and the substance of treaties that have been concluded between industrialized and developing countries. Issues discussed will include the measure of corporate profits, defenses to transfer pricing abuses, withholding taxes on investment income and the taxation of compensation. Issues of administrative cooperation, including information exchange and the arbitration of tax issues between treaty countries, will also be examined.