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Double taxation --- International taxation (Double taxation) --- Taxation, Double --- Taxation --- Conflict of laws --- Law and legislation

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This paper reviews recent international initiatives and domestic policy developments aimed at helping countries to protect their tax base against erosion by individuals and companies that allocate assets to or route income via low tax jurisdictions. The paper highlights the benefits and limitations of existing policy instruments from the perspective of capital-importing developing economies. Focusing on two common policy gaps for developing economies, options are explored for (i) introducing necessary charging provisions to ensure effective taxation of individuals, and (ii) an anti-diversion rule tailored to reflect developing economy contexts and administrative constraints. These proposals include a possible definition of excess profits in low tax jurisdictions and options for distribution keys to reallocate profits to countries where there is 'real' economic substance and activity. The measures discussed could also address the diversion of profits to entities benefitting from preferential regimes in countries with high nominal tax rates.

Diverted Profits Tax --- Governance --- International Taxation --- Law and Development --- Low Tax Jurisdictions --- Tax Law

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International business enterprises --- Double taxation --- International taxation (Double taxation) --- Taxation, Double --- Taxation --- Conflict of laws --- Law and legislation

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Double taxation. --- Double taxation --- International taxation (Double taxation) --- Taxation, Double --- Law and legislation --- Taxation --- Conflict of laws

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This publication is the condensed version of the OECD Model Tax Convention on Income and on Capital, which is produced in a loose-leaf format to accommodate yearly updates. This fifth edition contains the full text of the Model Tax Convention as it read on 28 January 2003, but without the historical notes, the detailed list of tax conventions between OECD member countries and the background reports that are included in the loose-leaf version.

Double taxation. --- Double taxation --- International taxation (Double taxation) --- Taxation, Double --- Taxation --- Conflict of laws --- Law and legislation