Tax Treaty Shopping and Developing Countries: Serious Potential for Tax Revenue Losses

Abstract

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are not, on average, more likely to suffer from tax revenue losses than other countries. Yet, this average masks that several countries, such as Bangladesh, Egypt, Kenya, Indonesia, Uganda and Zambia, are all vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The treaties responsible for this are referred to as potentially aggressive tax treaties. This is concluded by two Dutch economists and tax scholars, in a study commissioned by ICTD. Summary of Working Paper 173.