Regional Double Tax Treaty Models

Abstract

Abstract This chapter highlights regional double tax treaty models as potential indicators of regional tax treaty policy. Regional tax treaty models are often dismissed as being simple hybridizations of the ‘main’ model tax conventions, being the OECD Model Convention on Income and on Capital (the OECD MC) or the United Nations Model Double Taxation Convention between Developed and Developing Countries (UN MC). But insufficient attention to these models may be a missed opportunity to tease out regional tax treaty position or preferences. Regional tax treaty models emerge from economic groupings of countries and therefore should be a document that reflects that regional body’s preferences. The chapter evaluates the regional tax treaty models at the point of origination against the OECD MC and UN MC at that point in time. The chapter also examines the regional tax treaty models developed by regional economic groupings across the globe with the aim of assessing whether any unique positions or provisions emerge. The analysis is performed by comparing the regional models with both the OECD and UN Models in the public domain at the time the regional model was concluded. From the analysis, the aim is to prove or disprove whether regional tax treaty models reveal any regional tax treaty policy positions.