Africa and the Middle East have yet to be directly targeted by an OECD programme on taxation. African countries have recognised the need to foster regional trade and economic co-operation. Tax treaties can be a first step in this direction. As African countries increasingly enter into tax treaty negotiations they are seeking guidance and assistance in establishing tax treaty networks. The OECD is well placed to provide this assistance, given its experience in the area of international taxation and its work in other regions.

The most important existing tax treaties between African countries and developed countries are those concluded with former colonial powers. They do not in all cases reflect the interest of African countries in sufficient taxing rights and a safe revenue base. The programme will analyse the needs and interests of African countries and what the OECD Model can offer as orientation.

The programme will also discuss economic aspects of the division of taxing rights (capital export neutrality vs. capital import neutrality), the extent to which a taxing right of the source country is justified and reasonable, and the importance of taxation for investment decisions.