The following two model conventions are the basis for almost all of the several thousand worldwide DTAs.
The main purpose of the OECD Model Convention is to provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. The Council of the OECD has recommended that member countries, when concluding or revising DTAs between themselves, should conform to the current Model Convention and commentary, having regard to the relevant reservations expressed by countries.
The UN Model Convention is designed for developing countries and countries with economies in transition as a basis for negotiation of their DTAs. The Model helps to move forward in a way that preserves an appropriate share of taxing rights for developing countries. It also promotes cooperation to deal with tax avoidance and evasion. The Model and the UN Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries are reviewed and updated by the Committee of Experts on International Cooperation in Tax Matters.
The purpose of the OECD Model Agreement on Exchange of Information on Tax Matters (Model TIEA) is to promote international co-operation in tax matters through exchange of information. It was developed by the OECD Global Forum Working Group on Effective Exchange of Information and released in April 2002. The model represents the standard of effective exchange of information for the purposes of the OECD’s initiative on harmful tax practices. It is not a binding instrument but contains two models for bilateral agreements. A large number of bilateral agreements have been based on this Agreement. See all bilateral agreements.
The Global Forum on Transparency and Exchange of Information for Tax Purposes is the multilateral framework within which work in the area of tax transparency and exchange of information is carried out by over 100 jurisdictions. The Global Forum is charged with in-depth monitoring and peer review of the implementation of the standards of transparency and exchange of information for tax purposes. These standards are primarily reflected in the 2002 OECD Model Agreement on Exchange of Information on Tax Matters (Model TIEA) and its commentary, and in Article 26 of the OECD Model Tax Convention on Income and on Capital and its commentary as updated in 2004, which has been incorporated in the UN Model Tax Convention. The standards provide for international exchange on request of foreseeably relevant information for the administration or enforcement of the domestic tax laws of a requesting party.
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The OECD develops legal instruments, referred to as 'the OECD Acts' on a wide range of topics, including tax. The main types of Acts are Decisions and Recommendations. Other legal instruments developed by the OECD include Declarations and International Agreements.
All OECD Acts and other instruments in force are available in the Legal Instruments Database, and can be searched, or browsed by committee, type or theme. To find all legal instruments concerning international tax, choose 'international agreements' from the Type drop-down box and 'taxation' from the Theme drop-down box.
Here you will find the Convention on Mutual Administrative Assistance in Tax Matters, a multilateral treaty, of which 144 countries are signatories to. This treaty is also available in the UN Treaty Series. See also:
See the OECD Centre for Tax Policy and Administration for all conventions, working papers, reports, policies, news etc on the tax topics listed below.
To find international tax agreements, we recommend the following databases:
This database only includes DTAs, not other types of international agreements. It contains the full text of more than 10,000 treaties, amending protocols and similar documents. Up-to-date detailed country profiles are provided, as well as tools to directly compare both tax treaties and tax rates for every available jurisdiction. A useful feature is that individual Articles in all treaties have a link to the comparable Article in the OECD Model Treaty, so can be compared side by side. (Note: Users need to register and then sign on each time to access).
To find the full text of international treaties, search by country or go to the International Tax Treaties section. This database includes a large collection of international treaties and expert analysis. The Treaty Compare Tool enables you to easily compare treaties and against model treaties (OECD and UN). Users need to register to access, and then sign on each time.
To find international tax treaties in individual countries, use:
The majority of international tax agreements are bilateral, but may also be multilateral. Although the vast majority of multilateral treaties (and many bilateral treaties) are deposited with the UN and form part of the UN Treaty Series, there is no requirement for deposit. However, this is a good place to start and contains the most complete collection of international tax agreements from all countries.
The individual foreign legal research guides on the Law Library Research Guides webpage all have a Treaties page, which helps you find open access treaties for those countries.
The Treaties page in the Law Library's Public International Law research guide lists many open access treaty databases
The WorldLII International Treaties Collection provides access to full text treaties by country - but only approximately 70 countries are included.
See Citing treaties in AGLC4 style in the Public International Law research guide.