The Toolkit on Tax Treaty Negotiations of the Platform Collaboration on Tax is now updated with new tools, which are available in English, French and Spanish.


Explore these tools and existing ones at the links below in English, French and Spanish:

Web-based, interactive toolkit in English, French and Spanish

PDF version in English, French and Spanish


The PCT Toolkit provides capacity-building support in a critical area for developing countries. Building on existing resources, the toolkit offers practical and accessible guidance on the considerations and steps involved in tax treaty negotiations. The toolkit chapters offer easy access to practical guidance from existing resources, the staff of the PCT Partners and seasoned treaty negotiators on steps involved during the preparation for negotiations, the conduct of negotiations and post negotiation actions.

The toolkit features several references to several additional resources such as relevant databases, a calendar of training events by the PCT Partners and practical tips on the art of negotiation. These resources make the toolkit dynamic and amenable to regular updates. Since the launch of the toolkit, PCT Partners has added new tools and resources to the pdf and interactive, web-based versions of the toolkit or updated existing external resources and information in the following areas:


Toolkit Chapter

1. Example of agenda and list of participants


2. Checklist of logistics for conducting negotiations by videoconferencing


3. Checklist of information on a country’s tax system

C.8, C.9

4. Overview of main differences between UN and OECD Models


5. Example of side-by-side opening texts


6. Compared opening texts using brackets

C.10, D-1, D-3, D-7

7. Comparison of opening texts using colors and brackets

C.10, D-1, D-3, D-7

8. Example of deferred-effect provision


9. Example of preservation of benefit clause


10. Example of agreed minute

D.5, D.7

11. Example of sunset clause


12. Timeline of post-negotiation milestones

E.1, E.3, E.4

13. Template of full powers document


14. Examples of written explanations in English, French and Spanish


15. Examples of entry-into-force and entry-into-force provisions



These updates were recently discussed by the PCT experts in the first edition of the "Ask-An-Expert Series" which focused on Tax Treaty Negotiations on Toolkit, on June 15, 2022. More information on the webinar can be found on the event page.


Image credit: Karolina Grabowska