Source-Based Taxing Rights from the OECD to the UN Model Conventions: Unavailing Efforts and an Argument for Reform

Authors

Oladiwura Ayeyemi Eyitayo-OyesodeFollow

Document Type

Article

Publication Date

2020

Keywords

taxing rights, OECD, taxation treaties, Nigeria double taxation treaties

Abstract

A significant number of scholars have written about the nexus between fairness in the allocation of taxing rights in double taxation treaties and sustainable development in developing countries. These scholars have argued for expansive taxing rights for developing countries, as against the current source- restricting provisions in taxation treaties between developed and developing countries based on the OECD and UN Model taxation treaties. They have also highlighted the need for developing countries to critically assess their treaty networks, and to consider gaps in their local laws and policies that encourage revenue loss. This paper contributes to this body of knowledge by identifying provisions in Nigeria’s double taxation treaties that encourage revenue loss. It concludes by recommending amendments to Nigeria’s double taxation treaties.

Recommended Citation

Oladiwura Eyitayo-Oyesode, Source-Based Taxing Rights from the League to the OECD Model Convention 2014: Unavailing Efforts and the Formulary Solution, (2020) 13:1 L & Dev Rev 193.

Publication Abbreviation

L & Dev Rev