Tax Sparing : A Reconsideration

Tax sparing provisions have now more than four decades of history in bilateral tax treaties, including treaties between OECD countries. But the world of today is quite different from that when the positions of OECD Member and non-member countries towards tax sparing were developed. These changes in the international setting have led countries to reconsider their attitude towards tax sparing and the design of such provisions. This report examines the practices of Member countries and explains why Member countries have become more reluctant to grant tax sparing in treaties. It also provides a number of suggested "best practices" on the design of tax sparing provisions in tax treaties.