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.
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.