The CARICOM Double Taxation Agreement

• Author: Lynette Eastmond
• Pages: 65-77

65

The CARICOM Double Taxation Agreement

8

The CARICOM Double Taxation Agreement

Lynette V. Eastmond

1 The International Dimension

THERE ARE FOUR MODEL CONVENTIONS that have had some impact

on the negotiation of double taxation agreements within the region. These

four conventions are the United Nations model convention (UN Model), the

Organisation for Economic Cooperation and Development model convention

(OECD Model), the Andean model convention, and the United States of

America model agreement.

1.1 The League of Nations

Much of the early work on the formulation of the modern model double

taxation conventions has its origins within the League of Nations and the

desire of its members to work toward eliminating double taxation. In 1921,

the Financial Committee of the League of Nations mandated a team of four

economists to prepare a study on the economic aspects of international double

taxation.

Over almost 40 years, several studies were carried out concerning the

elimination of double taxation. During 1923 to 1927, the group drafted bi-

lateral conventions for the prevention of double taxation. The conventions

with their commentaries were sent to various governments, both members

and non-members. Several conferences were then held to discuss the subject.

After the Fiscal Commission and its committee stopped functioning in 1954

the work was continued by the Organisation for European Economic

Cooperation, subsequently named the Organisation for Economic Cooperation

and Development. 2