联合国贸发会议：2024年双重征税协定及其对投资的影响研究报告（英文版）（55页）.pdf

1、Double taxation treaties and their implications for investment:what investment policymakers need to knowDouble taxation treaties and their implications for investment:what investment policymakers need to knowGeneva 2024 2024,United NationsAll rights reserved worldwideRequests to reproduce excerpts o

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5、e United Nations Conference on Trade and DevelopmentUNCTAD/DIAE/PCB/2024/1ISBN:978-92-1-003056-4eISBN:978-92-1-358812-3Sales No.E.24.II.D.6TABLE OF CONTENTSACKNOWLEDGEMENTS.IVPREFACE.VEXECUTIVE SUMMARY:WHAT INVESTMENT POLICYMAKERS NEED TO KNOW ABOUT DTTS.VIINTRODUCTION.11.The reform of DTTs BEPS and

6、 beyond.32.Interaction between DTTs and investment policy.4SELECTED DTT PROVISIONS AND THEIR IMPACT ON INVESTMENT.71.Preamble.82.Personal scope.93.Substantive scope:taxes covered.154.Permanent establishments.175.Allocation rules.206.Methods for elimination of double taxation.267.Anti-abuse provision