Tax treaties

Toolkit on Tax Treaty Negotiations (Draft version)


Cover page of Toolkit For Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses - Discussion Draft

Published 29 June 2020


Access the toolkit (PDF)



The Platform for Collaboration on Tax (PCT) – a joint initiative of the IMF, OECD, UN and World Bank Group – has undertaken, at the request of the G20, the development of a series of "Toolkits" to help guide developing countries in the implementation of policy options for issues in international taxation of greatest relevance to these countries.

PCT's Draft Toolkit on Tax Treaty Negotiations is a joint effort to provide capacity-building support to developing countries on tax treaty negotiations, building on existing guidance, particularly from the UN Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (the "UN Manual"). The Toolkit describes the steps involved in tax treaty negotiations such as how to decide whether a comprehensive tax treaty is necessary, how to prepare for and conduct negotiations, and what follow-up measures to take after negotiations. Treaty negotiating teams, especially those who are new to the process, can also find practical tips on the conduct of negotiations and negotiation styles.

Additionally, the Toolkit collates links to already publicly available resources that treaty negotiators will find useful, making them easily accessible for treaty teams. The design of the Toolkit allows regular updates and improvements based on the feedback from users and experienced negotiators.


The PCT Secretariat is now seeking comments on the discussion draft of the Toolkit by 24 September 2020 from interested stakeholders. We welcome guidance on other questions that we should consider. We also welcome views on how to support developing countries in building effective tax treaty negotiation teams. Comments and inputs on the draft will be published and will be taken into consideration in finalising the toolkit.The PCT Secretariat aims to release the final toolkit in early 2021.



Questions to consider:

  1. Does this draft toolkit effectively address all the relevant technical and practical considerations as well as skills necessary to build capacity for tax treaty negotiations in developing countries
  2. Are there particular resources or tools, especially beneficial for developing countries, not covered in this toolkit that should be considered? 


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