Update on September 9, 2020

The PCT has extended the deadline for the public consultation on its draft Toolkit on Tax Treaty Negotiations.

The public consultation on the Toolkit on Tax Treaty Negotiations is now

accepting submissions until Thursday, September 24, 2020.

The PCT draft toolkit is available in English, French and Spanish.


Washington, D.C. – June 29, 2020 - The Platform for Collaboration on Tax (PCT) – a joint initiative of the IMF, OECD, UN and World Bank – is seeking feedback from the public on a draft toolkit designed to help developing countries build capacity in tax treaty negotiations. 

PCT’s Draft Toolkit on Tax Treaty Negotiations is a joint effort to provide capacity-building support to developing countries on tax treaty negotiations, building on existing guidance, particularly from the UN Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (the “UN Manual”). The Toolkit describes the steps involved in tax treaty negotiations such as how to decide whether a comprehensive tax treaty is necessary, how to prepare for and conduct negotiations, and what follow-up measures to take after negotiations. Treaty negotiating teams, especially those who are new to the process, can also find practical tips on the conduct of negotiations and negotiation styles.

Additionally, the Toolkit collates links to already publicly available resources that treaty negotiators will find useful, making them easily accessible for treaty teams. The design of the Toolkit allows regular updates and improvements based on the feedback from users and experienced negotiators.

The PCT Secretariat is now seeking comments on the discussion draft of the Toolkit by September 24, 2020 from interested stakeholders.  The PCT draft toolkit is available in English, French and SpanishComments can be sent in two ways:

  • All interested stakeholders: Please send your comments by e-mail to
  • Tax administrations and international or regional tax organizations can also provide their comments on the Knowledge Sharing Platform for Tax Administrations Web site (KSP-TA) by registering here

The PCT Secretariat aims to release the final toolkit in early 2021.

Questions to consider:

  1. Does this draft toolkit effectively address all the relevant technical and practical considerations as well as skills necessary to build capacity for tax treaty negotiations in developing countries?
  2. Are there particular resources or tools, especially beneficial for developing countries, not covered in this toolkit that should be considered?  

We welcome guidance on other questions that we should consider. We also welcome views on how to support developing countries in building effective tax treaty negotiation teams. Comments and inputs on the draft will be published and will be taken into consideration in finalizing the toolkit.

Please note that all comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.

Media queries should be directed to: