Second Regional Tax Forum: Intensive Course on International Tax Treaties for Selected Asian Countries

Objectives

The growth of international economic transactions has led to new pressures on tax administrations and new risks for businesses and investors. Taxpayers face the risk of double taxation in two jurisdictions, a risk that can inhibit and even stop some cross-border investments. At the same time, tax authorities face risks to collection from profit shifting. Both these issues can be resolved through the conclusion of bilateral tax treaties, which are the only international tools to divide taxing rights between countries, provide a mechanism for resolving disputes on profit shifting, and establish procedures for the exchange of information needed to tax multinational corporations properly. There are two important tax treaty models currently used, namely OECD and United Nations Models, which are very similar. In order to secure proper collection of income tax, to align the domestic law and practices with international standards, and to acquire sound knowledge and techniques for tax treaty negotiations, capacity building activities for senior tax officials for the subjects above and their related topics are, therefore, indispensable. To this end, three sub-regional intensive courses (i.e. selected Asia in 2009; the Pacific in 2010; and Central Asia in 2011) will be provided.

The main objective of the proposed Intensive Course on International Tax Treaties is to (i) provide tax policymakers and tax administrators with knowledge, technical details and their policy implications of international tax treaty models with key variations actually used in bilateral treaties for reference; and (ii) enhance policy capacity and technical skills among them for effective negotiations in such treaties that will efficiently avoid double taxation between tax authorities concerned.

In view of the above, this Intensive Course will address the following subjects:

1. OECD and United Nations Treaty Models;
2. Designing and drafting a domestic law to implement the treaties;
3. ASEAN policies on the Treaties, and the Thai experiences; and
4. Other related topics (e.g. Patterns in Asian tax treaties, and transfer pricing)

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Outputs

1. Better understanding of the two leading International Tax Treaty Models;
2. Improved capacity in international tax treaty negotiations on a bilateral basis;
3. Executive summary of proceedings to be prepared by 17 December 2009; and
4. Strengthened networking among participants and resource speakers.

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Participants

The proposed Intensive Course will be attended by 24 middle- to senior-level tax officials directly in charge of international tax treaty issues from the following 19 DMCs (as a rule, two officials per DMC for LDC category are invited in order to provide capacity building opportunity to those DMCs that are needed most): Afghanistan; Bangladesh; Bhutan; Cambodia; PRC; Hong Kong, China; Indonesia; Republic of Korea; Lao People’s Democratic Republic; Maldives; Mongolia; Myanmar; Nepal; Philippines; Singapore; Sri Lanka; Taipei,China; Timor Este; and Viet Nam. Tax officials from Hong Kong, China; Republic of Korea; Singapore; and Taipei,China will be requested to fund for their participation.

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Partners

International Bureau of Fiscal Documentation (IBFD), Amsterdam; International Monetary Fund (IMF), Washington, D.C.; Organisation for Economic Co-operation and Development (OECD), Paris; United Nations, New York; Monash University (Australia) and other academics; and Governments of Japan and Thailand