Tax treaties

Toolkit on Tax Treaty Negotiations


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

Published 10 March 2021


Access the toolkit


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.

The PCT's 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 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 toolkit provides:

  • Practical tips & knowledge on the steps involved in tax treaty negotiations
  • Easy access to publicly available resources that treaty negotiators will find useful


Launch Workshop of the Toolkit on Tax Treaty Negotiations

11-12 & 15 March 2021 | 9:00 AM - 12:00 PM ET (Washington, DC)

The PCT will run a three-day workshop for the official launch of the final version of the Toolkit on Tax Treaty Negotiations, including its full web-based version. The virtual workshop will feature expert speakers and experienced negotiators, who will discuss some of the substantive issues addressed in the toolkit. Topics include designing a tax treaty policy framework and the steps involved in the preparation for, conduct of and follow-up after negotiations. Participants will also learn about different tax treaty databases offered by NGOs.


Press release


Public consultation

In June 2020, the PCT invited public comments on the draft version of the Toolkit on Tax Treaty Negotiations. The final toolkit takes into account public comments received from June to September 2020 and public consultation webinars held in EnglishFrench and Spanish in November and December 2020.


Draft versions of the toolkit


Further information


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