Analysis of Imbalanced Tax Treaties of

10 However, according to a study released by ActionAid, in the context of the rise of multinational companies, the tax treaties between developing and developed countries are depriving the world’s poorest countries of vital revenue.11 The treaties are restrictive to developing countries, limiting their tax rights. [...] In order to assign scores to each bilateral treaty, the TTE dataset analyzes five indices that combine the overall content of the treaty into a score from 0 to 1, with a score of 1 representing greater taxing rights over inward investment.14 The five indices are as follows:15 Source: All fields in the dataset that relate to the balance of taxing rights. [...] By comparing the average scores of all treaties with those of treaties that have a source tax index score of 0.4 or lower, the level of significance in difference between the two groups was revealed. [...] WHT on Dividends The provision under Article 10(2)(a) of the UN Model allows for the taxation of dividends in the company's resident State, with a maximum tax rate specified based on the beneficial owner's ownership percentage in the paying company (known as the threshold for qualified dividends). [...] of treaties not taxing gains from the sale of shares tied to immovable 76 property Total 183 Similarly, Article 13(5) of the UN Model permits a Contracting State to tax gains from the sale of shares or comparable interests in a company if the seller holds more than a specified percentage of the company's capital and the company is a resident of that State.