The Tax Treaties Explorer: New Data for Better Negotiation

International Centre for Tax and Development
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TAX TREATIES EXPLORER :
NEW DATA FOR BETTER
NEGOTIATION
1st December 2021

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The Platform for Collaboration on Tax (PCT)
The Toolkit on Tax Treaty Negotiations
1 December 2021
Presented by
Ms. Ashima Neb
Domestic Resource Mobilization Specialist
PCT Secretariat

4
Platform for Collaboration on Tax
Why The Toolkit?
• Existing Resources:
– UN Manual on Negotiation of Tax Treaties between
developing and developed countries : last update 2019
– Model Treaties: UN Model: Last update 2021 and OECD
Model last update 2017 (published 2018)
• Joint guidance by all PCT Partners: IMF,
OECD, UN and the WB
• Entry point to existing but disperse guidance
on specific issues through references and
links
• Links to practical resources such as:
– Calendar of training events of the four PCT Partners,
– Public and commercial tax treaty databases e.g., Tax
Treaties Explorer Tool,
– Additional examples such as those of specific types of
provisions and methods of display of drafts for
negotiation.

5
Key Features of The Toolkit
Facilitates informed
decision making but does
not set standards
Accessible and practical
Dynamic: amenable to
regular updates
Both online and PDF versions
are available in English,
French and Spanish
For online and pdf versions of the
toolkit, please visit:
www.tax-platform.org/publications

6
Structure of The Toolkit
A: Why negotiate tax treaties?
B: Tax treaty policy framework and
country’s model tax treaty
C: Preparing for tax treaty negotiation
D: Conduct of Negotiations
E: Post negotiation activities

7
• Non-tax reasons for entering into tax treaties must
be considered critically;
• Potential costs and benefits of a tax treaty and
alternative ways of achieving policy objectives
must be considered;
• Risks of double-taxation and non-taxation must be
considered;
• Provisions in tax treaties are administered through
domestic laws and administrative capabilities-
these must be in place;
• Administrative capacities and availability of
resources must be considered.

8
• The toolkit recommends that countries formulate
their tax treaty policy laying out the objectives they
want to achieve by entering into tax treaties;
• The policy should lay down country priorities, areas
of flexibility and areas of minimum agreements;
• The policy should also be aligned with domestic law
and commitments under international and/or
regional agreements;
• It also recommends having a model tax treaty as a
basis for treaty negotiations-structured on the
OECD or the UN Models.

9
• Authority to enter into negotiations based on internal
processes;
• Ministry of Finance in lead; other stakeholders to be
consulted;
• In person negotiations – post-pandemic negotiation
through video conferencing in some circumstances
has also been found useful;
• Identification of non-negotiable provisions and
alternative provisions;
• Logistical preparations including venue and the
exchange of
– models or draft for discussion,
– summary of domestic tax system and its interaction
with treaties,
– list of members of the negotiating team;

10
• Practical tips on negotiating styles and
soft skills for effective negotiations
• Completion of formalities for signature of
the agreed treaty by both sides
• Translation of texts
• Steps before entry into force and after
entry into effect

11
0 500 1000 1500 2000
French
Spanish
English
274
296
1665
172
217
1279
Unique Users Total Page Views
Online Toolkit Views (March-November 2021)

THANK YOU!
For questions, please contact us at taxcollaborationplatform@worldbank.org

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Martin Hearson
The Tax Treaties
Explorer
Research Fellow

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Motivation
1. Analysis of existing treaties and preparation for
(re)negotiation is costly and time-consuming
2. Hard to communicate urgent priorities to
policymakers
3. Little research on the impact of treaty content

www.ictd.ac
Treaties.tax
 Free to access (EN/FR)
 2500 treaties & amendments, 28 provisions
 Quick and easy clause-by-clause comparison
 Indexes for high-level comparison
 Produce visualisations that communicate to a wider
audience
 A living tool
 Complements analysis of treaty text, but does not
substitute for it

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Clauses and indices included
5(3)(a) PE definition: construction PE length in months
5(3)(a) PE definition: supervisory activities associated with construction
5(3)(b) PE definition: service PE length in months
5(4)(a) PE definition: delivery exception to PE
5(4)(b) PE definition: delivery exception to PE
5(5)(b) PE definition: stock agent PE
5(6) PE definition: insurance PE
5(7) PE definition: dependent agent extension
10(2)(a) WHT rate: qualifying [FDI] dividend WHT in %
10(2)(b) WHT rate: other [portfolio] dividend WHT in %
11(2) WHT rate: general interest WHT in %
11(2)
WHT rate: interest rate WHT applying to loans from banks and
financial institutions in %
12(2) WHT rate: general royalties WHT in %
12A Management or technical service fees in %
12(2) WHT rate: royalties WHT applying to payments for copyright in %
12(2)
WHT rate: royalties WHT applying to payments for the use of
equipment in %
7(1)(b&c) Limited force of attraction
7(3) No deduction for payments to head office
8(2) Source shipping right as a %
13(4) Source capital gains on 'Land rich' company
13(5) Source capital gains on shares other than those covered by 13(4)
14 Independent personal services included
16(2) Source taxation of earnings by top-level managerial officials
21(3) Source taxation of other income
Permanent
establishment
definition
Withholding
tax rate
Other
provisions
Index of
overall source
taxing rights
UN model
index
Also included in the data:
10(2)(a) Threshold for qualifying dividends
25B(5) Mandatory binding arbitration
27 Assistance in collection
29 Entitlement to benefits

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Standardised and simplified coding
 Important details that vary from the OECD/UN models may not
be captured
 Coding book online clarifies how common variations are coded
 Always check the treaty text!
 Domestic law not considered
Example: fees for technical services (12A)
12 royalty definition v 12A standalone article v Protocol
Management v technical service v consultancy fees
Only the rate
is coded
(0 if absent)

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Treaties.tax

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Martin Hearson
Illustrative findings from the
Tax Treaties Explorer data
Research Fellow
1 December 2021

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1. Illustrative findings

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Changes in Indexes Measuring the Overall
Balance of Taxing Rights

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Evolution of Main WHT Rates within Treaties in
Force

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Evolution of Various PE Provisions within
Treaties in Force

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Presence of New Model Treaty Provisions
(Excluding MLI)

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Impact of the MLI

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Impact on the Overall Source Taxing Rights from Renegotiations
since 2010

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Source Index of new treaties between
India, China and LICs

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2. Replication study

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Replication Study: Tax Treaties and FDI
 Barthel, Busse & Neumayer (2009), "The Impact of Double
Taxation Treaties on Foreign Direct Investment: Evidence from
Large Dyadic Panel Data.“
 A tax treaty between two countries increases the stock of FDI by 30%
 Unlike newer studies, does not account for treaty shopping
 Replication asks how the content of a treaty affects FDI. In our
preferred model:
 Lower source index => higher FDI
 Lower WHT rates index => higher FDI
 Lower PE, Other, UN index => no change in FDI

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New data
More
relevant
research
Stronger
treaty
networks

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Tatiana Falcão
Past, present and future of
article 8 (alternative B) of the
UN Model
1st December 2021

1. Working Paper Research Questions
• What is the historic background of Article 8 of the OECD Model
 principle of exclusive residence state taxation of shipping profits
• Why was Article 8 (Alternative B) included in the UN Model?
 shared source/residence state taxation of shipping profits
• What is the current status of inclusion of Article 8B in the bilateral tax treaty
network
• What can African coastal countries learn from countries that have succesfully
adopted 8B in their tax treaty policies

2. Inclusion of Article 8 (Alternative B) in the bilateral tax treaty
network (1/6)
• Article 8(1) of the OECD Model and Alternative A of the UN Model:
'Profits of an enterprise of a Contracting State from the operation of ships or aircraft in
international traffic shall be taxable only in that State.’
• Article 8 (Alternative B)(2) of the UN Model
'Profits of an enterprise of a Contracting State from the operation of ships in international traffic shall be
taxable only in that State unless the shipping activities arising from such operation in the other Contracting
State are more than casual. If such activities are more than casual, such profits may be taxed in that other
State. The profits to be taxed in that other State shall be determined on the basis of an appropriate allocation of the
overall net profits derived by the enterprise from its shipping operations. The tax computed in accordance with such
allocation shall then be reduced by ___ per cent. (The percentage is to be established through bilateral
negotiations.)’
• Income covered/sourcing rule?
• Source country taxing rights?
• Residence country taxing rights?
• Method of taxation?

ICTD Tax Treaties Explorer – World Map – Article 8 (Alternative B) of the UN Model
network (2/6)

• be taxable only in that State.’
• le 8(1) of the OECD Model and Alternative A of the UN Model:
'Profits of an enterprise of a Contracting State from the operation of ships or aircraft in
international traffic shall be taxable only in that State.’
network (3/6)
• Inclusion rate in low and lower-middle income countries
(dataset Tax Treaties Explorer):
• 266 out of 1,876 treaties have source taxation
• inclusion rate of 14% overall
• Low rate, unsuccessful policy?
• Spread of the treaties with 8B is very regional phenomenon
• Not relevant to land-locked countries
• Highly concentrated in a few coast countries
• 8 countries in South and South East Asia are
responsible for 200 out of the 266 relevant tax treaties
• Standard tax treaty policy in:
• Bangladesh (91%), India (17%), Indonesia (19%),
Myanmar (100%), Pakistan (43%), Philippines
(100%), Sri Lanka (95%) and Thailand (86%)

network (4/6)

network (5/6)

3. Conclusions: should a country adopt Article 8 (Alternative B)?
• (South-south) policy recommendations based on existing policy:
• Economic considerations:
• Revenue, fleet protection and environmental concerns
• Geographic location of country in question
• Treaty network and negotiation considerations
• Are tax treaties necessary?
• Choice of tax treaty partner?
• Countering arguments pro exclusive residence state taxation
• Not part of residence state tax treaty policy?
• Historic consensus?
• Enforceability and compliance issues?
• Lack of guidance in UN Model on profit attribution
• Impact on shipping company profit margins

3. Conclusions: should a country adopt Article 8 (Alternative B)?
• Considerations regarding the drafting of the provision:
• Income covered
• No activity threshold
• Not ideal for air transport income
• Indirectly related and ancillary activity profits
• Source state taxing rights
• Proportional limit of source tax of between 40 and 66%
• Absolute (gross) tax limits not ideal
• Sourcing rule
• Variation of sourcing rules (no rule, open rule or limited rule)
• Limited sourcing rule (place of activities rather than payor) is optimal
• Method of taxation and interaction with domestic tax law
• Gross taxation in practice
• Gross taxation with net tax alternative is optimal approach

Thank you for your attention!
Working Paper and Blog available at:
https://www.ictd.ac/publication/taxing-
profits-international-maritime-shipping-
africa-past-present-future-un-model-article-
8-alternative-b/
https://www.ictd.ac/blog/time-reinforce-un-
model-taxing-international-shipping-profits/
The authors can be contacted at:
Bob Michel: Michel.bob@gmail.com
Tatiana Falcao: Tatiana.Falcao@yahoo.com.br

Tax treaty
aggressiveness:
Who is undermining
taxing rights in
Africa?
1st December, 2021
Lucas MillánNarotzky
Senior researcher
Tax Justice Network

Contents
1. Challenging common assumptions
2. FormalisationsofAggressiveness
3. Results

1.
Challenging common assumptions

‘To convene or not to convene’
• Tax treaties are meant to prevent double taxation
• Yet unilateral tax credit systems can prevent most double taxation
• A badly negotiated treaty can sustain or create dynamics of economic control
• Example Vietnam-France treaty (1993), 0% WHT Interests
• Tax treaties should not be signed with additional FDI in mind
• Meta-studies show no significant effect
• From 40% to 80% or more of FDI is composed of “phantom FDI” or M&A…
not real economic activity.
• FDI often leads to the worsening of labour conditions and environmental
degradation
Sources: Dagan 2000; Brada et al. 2021; Damgaard et al. 2019; Chang 2011; Head & Ries 2008; Durand 2007;
Jorgenson 2007; Long et al. 2017; Maconachie et al. 2015

Different goals, different models
• OECD model protects interests of capital exporters (investor companies) awarding
effective exemptions
• UN model favors taxation at source, to promote domestic revenue mobilisation
• Shift to source-based negotiation positions and emergence of alternative model tax
conventions (ATAF)
Treaty provision OECD model UN model
Withholding taxes 5/15% Dividends; 10% Interests; 0%
Royalties; 0% Services
Left for negotiation by partners
Article 12A taxation of services at source
Permanent Establishment Includes various exceptions (insurance,
dependent agents, construction PE…)
Minimal exceptions to PE.
Other treaty provisions No taxation of Shipping rights at source,
deduction of head office payments, no
taxation of cap. gains of land rich
companies
Source taxation is protected for each
income realisation event.

Evolution of WHT rates: araceto the bottom?
Figure 1.2 Evolution of treaty withholding rates in treaties with African
countries signed 1970-2017. [lowess plotting method] Source: Authors

Symmetricdesigns for unequal partners
Figure 1.1 Net greenfield FDI positions from OECD data by income level Source: Authors

Unequal partners,inequitableoutcomes
Country Annual Tax losses Source
Philippines,Pakistanand
Bangladesh
$800000000 Janský& Šedivý2019
Netherlands’treatypartners €770000000 McGauran2013
US’non-OECDtreatypartners $1600000000 IMF 2014
Ukraine $300000000 Balabushkoetal. 2017
SouthAfrica $410000000 Janskýetal. 2020

ResearchQuestions
 Which countries are most aggressive in reducing
taxing rights through tax treaties in Africa?
 How sensitive are the findings to different
measures of treaty content and aggressiveness?

2.
Formalizations of aggressiveness

A definition of treaty aggressiveness
An aggressive treaty is that which reduces source tax
rights more acutely than other treaties in force in the
source jurisdiction.
Why?
 Source taxation is essential to domestic resource mobilization (DRM),
and in order to attain SDGs.
 Treaties that most intensely reduce source taxing rights can be
considered as most hostile or aggressive towards low-income countries,
because these treaties make it harder to raise revenues that are
needed for development.

Ways in which a treaty can be aggressive
Example 1: Republic of Congo
 Domestic law: WHT rates are 15 – 20%.
 Mauritius-Congo treaty: limits WHT to 0 – 5 % (all types of payments).
Example 2: Republic of Congo
 Domestic law: when Congo real estate is bought and sold by resident companies or individuals,
the jurisdiction has the right to tax the capital gains derived therefrom.
 Mauritius-Congo treaty: Congo is not allowed to tax capital gains from the sale of shares of a
Mauritius company with substantial real estate holdings in Congo.

Ways in which a treaty can be aggressive
What data is available to systematically analyse treaty
aggressiveness accross Africa?
What different types of aggressiveness can be assessed
with available data?

Whithholding tax data
IBFD ICTD
Raw treaty rates
WHT dividend Qualifying and non-qualifying FDI and portfolio
WHT interest Main and qualifying rates Main and loans from banks
WHT royalty Main and qualifying rates Main, copyright and equipment
WHT services - Technical/management fees
Raw domestic rates (IBFD only)
WHT dividend Main and qualifying rates
WHT interest Main and qualifying rates
WHT royalty Main and qualifying rates

StatisticalcomparisonIBFD andICTD
• Coverage : 455 treaties in force
• 415 (91.2%) were found in both sources,
• 10 only in IBFD
• 30 only in ICTD
• 3 Multilateral treaties (WAEMU, AEUC, CEMAC)
• Accuracy
Good correlation between the two
sources (Spearman’s rank
coefficients of 95, 83 and 93%
respectively).
Source: Authors

Quick descriptionof ICTD data
• Withholding rates -------------------------- 4 types of WHT
• Permanent Establishment scope -------------------- 8 vars.
• Construction PE length?
• Exceptions for insurance, agents, supervisory activities?
• Other treaty provisions ------------------------------- 8 vars.
• Source taxation of shipping rights
• Deduction of payments to head office
• Taxation of capital gains on domestic shares

Modelisation
Country i Country j WHT Div Average
excl. i
𝑘𝑗,𝑖 − 𝑘𝑖𝑗 𝑫𝒊𝒋
𝒌
Singapore Rwanda 7.5 10.625 3.125 3.125
Jersey Rwanda 10 10 0 0
Belgium Rwanda 7.5 10.625 3.125 3.125
Mauritius Rwanda 10 10 0 0
South Africa Rwanda 15 8.75 -6.25 0
𝐷𝑖𝑗
𝑘
=
𝑘𝑗,𝑖 − 𝑘𝑖𝑗
0
𝑖𝑓 𝑘𝑗,𝑖 − 𝑘𝑖𝑗 > 0
𝑜𝑡ℎ𝑒𝑟𝑤𝑖𝑠𝑒
,
Example:
Aggressiveness for
Dividends
withholding in
Rwanda
Source: Authors

Types of aggressiveness
Name Measurement Components k
M1-IBFD WHT Raw treaty WHT rates on dividends, interest and
royalties
M1-ICTD WHT Raw treaty WHT rates on dividends, interest,
royalties and services
M2-IBFD WHT DOM Raw treaty and domestic WHT rates on dividends,
interest and royalties
M3-ICTD WHT Coded treaty WHT rates on dividends, interest,
royalties and services
M4-ICTD SI Indices WHT rates, PE and Other treaty provisions

Treaty WHT aggressiveness
UAE
Mauritius
and France…
negotiate the
lowest WHT, in
comparison to
other treaties
signed by African
countries.
Source: Authors

Treaty/DomesticWHT aggressiveness
France,
United Kingom,
Mauritius and
UAE…
negotiate the
lowest WHT, in
comparison to
African countries’
domestic WHT.
Source: Authors

Treaty/DomesticWHT aggressiveness
France,
United Kingom,
Italy and Germany…
negotiate the treaties
that most reduce
African countries’ tax
rights, when
considering
Permanent
Establishment and
Other treaty
provisions
Source: Authors

Different aggressivenessprofiles
Assessed country African treaty partner Treaty agg.
measure with
M4
% aggressiveness derived from
WHT PE Other
France Guinea 1.00 0% 75% 25%
France Libya 0.86 59% 40% 1%
France Namibia 0.71 13% 65% 22%
United Kingdom Eswatini 0.89 25% 59% 16%
United Kingdom Egypt 0.79 15% 61% 24%
United Kingdom Morocco 0.74 0% 60% 40%
Mauritius Tunisia 0.65 67% 5% 29%
Mauritius Madagascar 0.63 55% 45% 0%
Mauritius Congo, Rep. 0.46 46% 0% 54%
United Arab Emirates Guinea 0.57 56% 0% 44%
United Arab Emirates Tunisia 0.51 64% 0% 36%
United Arab Emirates Mozambique 0.46 72% 10% 18%
Source: Authors

How can aggressiveness measures be used for treaty
(re)negotiation?
African country
(excl. Mauritius and
Seychelles)
Total # of
treaties of
African
country
Intensity of
agg. of this
particular
treaty
Share of
total agg.
received by
this African
country
Principal aggressor (most
aggressive treaty partner of
African country)
SEN Senegal 23 35.827.9% Qatar QAT
TZA Tanzania 9 33.832.8% India IND
MDG Madagascar 2 30100.0% Mauritius MUS
TUN Tunisia 55 29.99.4% Mauritius MUS
DZA Algeria 35 29.418.0% Bahrain BHR
ZMB Zambia 22 28.127.2% France FRA
MOZ Mozambique 8 26.751.1% United Arab Emirates ARE
GMB Gambia 6 26.545.5% Switzerland CHE
ZWE Zimbabwe 15 25.730.6% Kuwait KWT
GIN Guinea 3 25.493.8% United Arab Emirates ARE
According to Model 1-ICTD (Treaty WHT)
Source: Authors

Mozambique – UAE example (Treaty WHT aggressiveness)
Source: Authors
African
partner
Assessed
country
Agg.
M1-ICTD
agg_par
tner_M1
-ICTD
DIV INT ROY SER Agg. DIV Agg. INT
Agg.
ROY
Agg-SER
MOZ United Arab
Emirates 26.7 51.1 0.0 0.0 1.7 0.0 10.9 8.0 6.1 1.7
MOZ South Africa 9.2 17.6 11.5 4.0 3.3 0.0 0.0 3.3 4.2 1.7
MOZ Mauritius 9.2 17.6 11.5 4.0 3.3 0.0 0.0 3.3 4.2 1.7
MOZ India 3.8 7.3 7.5 10.0 10.0 0.0 2.2 0.0 0.0 1.7
MOZ Italy 1.7 3.2 15.0 10.0 10.0 0.0 0.0 0.0 0.0 1.7
MOZ Portugal 1.7 3.2 10.0 10.0 10.0 0.0 0.0 0.0 0.0 1.7
MOZ Macao 0.0 0.0 10.0 10.0 10.0 10.0 0.0 0.0 0.0 0.0

86
African country
Seychelles)
Total # of
treaties of
African
country
Intensity of
agg. of this
particular
treaty
Share of
total agg.
received by
this African
country
African country)
MOZ Mozambique 8 50 20.3% United Arab Emirates* ARE
SLE Sierra Leone 3 50 52.6% Norway* NOR
DZA Algeria 35 49.4 5.9% Qatar* QAT
ZMB Zambia 22 47.5 11.7% Tanzania* TZA
GIN Guinea 3 40 55.2% United Arab Emirates* ARE
TUN Tunisia 55 39.6 5.1% Mauritius* MUS
ZAF South Africa 79 33.8 2.5% Netherlands NLD
MLI Mali 12 31.6 13.2% Russia* RUS
COG Congo, Rep. 5 30.8 29.1% Mauritius* MUS
MWI Malawi 5 30 38.7% United Kingdom* GBR
According to Model 2-IBFD (Domestic/Treaty rates)
Source: Authors
How can aggressiveness measures be used for
treaty (re)negotiation?

Sierra Leone/ Norway example (Treaty/domestic WHT agg.)
Source: Authors
African
partner
Assessed
country
Agg.
M2-IBFD
% Agg. DIV INT ROY Agg.
DIV
Agg.
INT
Agg.
ROY
SLE Norway 50
52.6315
8 0 0 0 10 15 25
SLE
United
Kingdom 35
36.8421
1 0 0 10 25
SLE South Africa 10
10.5263
2 0 10
DIV INT ROY
Domestic WHT 10% 15% 25%

African country
Seychelles)
Total # of
treaties of
African
country
Intensity of
agg. of this
particular
treaty
Share of
total agg.
received by
this African
country
African country)
EGY Egypt 61 1 6.8% Austria* AUT
GIN Guinea 3 1 63.8% France FRA
DZA Algeria 35 0.9 10.9% Spain* ESP
LBY Libya 21 0.9 16.9% Singapore* SGP
KEN Kenya 15 0.9 17.4% South Korea* KOR
SWZ Eswatini 5 0.9 62.5% United Kingdom* GBR
GNB Guinea-Bissau 8 0.8 100.0% Portugal* PRT
MAR Morocco 56 0.8 5.1% Germany* DEU
BEN Benin 9 0.8 81.0% Norway* NOR
ZAF South Africa 79 0.8 4.2% Netherlands NLD
According to Model 4-ICTD (Source Index)
Source: Authors
How can aggressiveness measures be used for treaty
(re)negotiation?

Guinea-Bissau /Portugal example (Source Index agg.)
Source: Authors
African
Partner
Assessed
Country
Agg.
M4-ICTD% Agg
Source
Index PE
Source
Index
WHT
Source
Index
Other Agg. PE
Agg.
WHT
Agg.
Other
GNB Portugal 0.8 100 0.1 0.3 0.3 0.5 0.2 0.1
GNB Benin 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB
Burkina
Faso 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB
Cote
d'Ivoire 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB Mali 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB Niger 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB Senegal 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0
GNB Togo 0.0 0 0.6 0.5 0.4 0.0 0.0 0.0

Interestingmethodologicalnuances
African
country
Treaty
partner
Source
Index
value
M4-ICTD
(by treaty)
WHT
Source
Index
WHT
M4 Agg.
PE
Source
Index
PE
M4 Agg.
Other
Source
Index
Other
M4 Agg.
Egypt Italy 0.43 0.68 0.94 0.00 0.09 0.49 0.25 0.19
Egypt China 0.42 0.24 0.33 0.17 0.56 0.01 0.38 0.06
Tanzania India 0.64 0.43 0.34 0.43 0.95 0.00 0.63 0.00
Tanzania Italy 0.39 0.30 0.72 0.01 0.19 0.15 0.25 0.14
South Africa Brazil 0.40 0.29 0.59 0.00 0.09 0.29 0.50 0.00
South Africa Algeria 0.38 0.04 0.41 0.00 0.34 0.04 0.38 0.00
Note: the colour coding above reflects that in M4-ICTD, higher values correspond to more aggressive treaties,
whereas in the Source Index, higher values correspond to treaties that are more favourable to source countries.
Source: Authors

Cluster analysis
Gulf countries,
Mauritius,
Seychelles and
China, much
more aggressive
with regards to
Withholding
rates
Source: Authors

Cluster analysis
EU28, OECD, G20
and G7 much
more aggressive
with regards to
PE and Other
treaty
provisions…
Source: Authors

Conclusions
 France’s aggressiveness highlighted in all models
 UK and other European countries for PE and Other
 UAE and Mauritius for WHT
 G7, G20, OECD disproportionately aggressive in
relation to more complex PE and other provisions
 Adherence to the OECD model convention…

Conclusions
 High income treaty partners undermine African domestic
resource mobilisation the most
 Aggressiveness measures show what treaties undermine or
could undermine source tax rights the most
 Targeting change: we specify what provisions would have
most impact upon treaty cancellation / renegotiation

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The Tax Treaties Explorer: New Data for Better Negotiation

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Editor's Notes