Negotiating Bilateral Tax Treaties: Should Tax Treaties Involving Low-income Countries Contain a Sunset Clause?

Authors

Okanga Ogbu Okanga, Dalhousie University Schulich School of LawFollow

Document Type

Report

Publication Date

2022

Abstract

This policy brief reflects on an underexplored proposition: that bilateral tax treaties – particularly treaties involving (middle- and) low-income countries – should contain an expiration or sunset clause. The brief examines some reasons why it may be sensible for a low-income country to make its bilateral tax treaty expirable, from its onset. It also highlights a few reasons why such a policy may not be advisable – or tenable. The brief concludes by exploring the design of a model sunset clause for inclusion in the UN Model Tax Convention.

Comments

Attribution-NonCommercial-NoDerivs 3.0 United States.

Recommended Citation

Okanga Ogbu Okanga, "Negotiating Bilateral Tax Treaties: Should Tax Treaties Involving Low-income Countries Contain a Sunset Clause?" (2022) University of Nairobi, Committee on Fiscal Studies, Policy Brief No 22.