IMF, OECD, UN, and World Bank Group Launches Tax Treaty Negotiations Toolkit

The Platform for Collaboration on Tax (PCT) — a joint initiative of the IMF, OECD, UN, and World Bank Group – released the final version of the Toolkit on Tax Treaty Negotiations along with its web-based, interactive edition.

The PCT’s Toolkit on Tax Treaty Negotiations is an 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 new to the process, can also find practical tips on the conduct of negotiations and negotiation styles. Additionally, the toolkit collates links to publicly available resources that treaty negotiators will find useful, making them easily accessible. The design of the toolkit allows regular updates and improvements based on the feedback from users and experienced negotiators.


This is the fifth toolkit published by the PCT, a collective effort of the PCT Partners to help countries address challenges in international taxation. The final version of the toolkit takes into account extensive comments received from countries and stakeholders during the public consultation process in June–September 2020. In addition to written comments, public consultation webinars, which were held in English, French, and Spanish in November and December 2020, gathered further feedback from diverse stakeholders, particularly treaty negotiation teams.

Following the release, the Toolkit on Tax Treaty Negotiations, including its full web-based version, will be launched at a three-day workshop on March 11, 12, and 15, 2021. The virtual workshop will feature expert speakers and experienced negotiators, who will discuss some of the substantive issues addressed in the toolkit, such as designing a tax treaty policy framework and the steps involved in the preparation for, conduct of, and follow-up after negotiations.

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