| Abstract [eng] |
The Master's thesis analyses models of double taxation agreements. The main focus is on the analysis of the provisions of the most recent versions of the Organisation for Economic Co-operation and Development (OECD) and United Nations (UN) model double taxation conventions (and their commentaries). The first part of the paper aims to analyse the “benchmark” of double taxation treaties, the OECD Model Convention. It analyses the articles (parts of articles) that differ from the text of the UN Model Convention and seeks to identify which type of countries are favoured by this model - those importing or exporting capital. The second sub-section examines potential amendments to the Model Convention. It seeks to determine how the current regime will change and analyses the prospects for the adoption of each proposed amendment. The second sub-section compares the second most frequently used model convention, the UN. The aim is to compare the provisions of this model convention (and its commentary) with those of the OECD model and to identify how each of its features makes the UN model more favourable to capital-importing countries. It also focuses on the amendments to the UN Model Convention that have already been adopted and analyses the impact they may have on developing countries and their tax revenues. Attention is paid to the multilateral convention. Given that the text of this convention is not expected to be ready until 2027, it examines what changes this convention is expected to introduce into the international tax system. It also examines the prospects for its adoption and the real impact it will have. |
