AN OVERVIEW OF TAX TREATY MODELS AND THE REVIWED

SADC MODEL DOUBLE TAX AVOIDANCE AGREEMENT

INDEX

I. INTRODUCTION 2
II. INTERNATIONAL TAX TREATY MODELS
1. INTERNATIONAL BACKGROUND 2
2. RECENT DEVELOPMENTS 5
III. SADC DOUBLE TAX AVOIDANCE AGREEMNTS MODEL
1. BACKGROUND 7
2. REVIEW OF THE SADC MODEL DTAA 9
i. REVIEW PROCESS
ii. SPECIFIC CHANGES AND CONSIDERATIONS
iii. SUMMARY OF THE KEY CHANGES TO THE
SADC MODEL DTAA AND COMMENTARY
IV. CONCLUSION 14
BIBLIOGRAPHY 15
 I. INTRODUCTION
Tax Treaties have changed the world’s economic relations, dating back to World War
I’s devastating global effects, which catalysed world states to intensify efforts to
increase international cooperation and mutually support economic development.
Double Tax Avoidance Agreements, or simply, Tax Treaties have been very effective
to this end, as these treaties bring States to a negotiation table, who then find the best
treaty with the tax sharing provisions that represents the needs of all parties. States
with very divergent policy priorities find in a Tax Treaty, ways to converge and
cooperate. Tax Treaty Models have been an essential tool to achieve such
convergence and to standardize the process. This paper will incur on a brief
international historical background of some relevant international Tax Treaty Models
and will then focus on the SADC Model and its most recent review process. Through
the SADC Model Double Tax Avoidance Agreement, which is now up to date with
global developments and focuses on the region’s needs, SADC Member States have
agreed on the policy orientation for their treaties within and beyond the region.

II. INTERNATIONAL TAX TREATY MODELS

1. INTERNATIONAL BACKGROUND
Under the Vienna Convention on the Law of Treaties, Treaties are agreements
between sovereign nations. Article 2, which applies to all treaties, provides that a treaty
is an international agreement concluded between States and governed by
international law. In the field of taxation, we can name are a few types of treaties: Tax
Information Exchange Agreements, Mutual Administrative Assistance Agreements
and Double Tax Avoidance Agreements (the subject matter of this paper).

Double Tax Avoidance Treaties or Agreements, or simply, Tax Treaties are

international agreements (usually bilateral but may be multilateral1) negotiated and
signed between states or jurisdictions, containing the terms and conditions for how the
parties will share the rights to tax income from cross-border economic activities.
Essentially, Tax Treaties set limits on when, and in some cases at what rate,
signatories can tax the income from that economic activity, primarily by imposing
restrictions on countries’ ability to tax the foreign direct investment that they receive.

1
Such as the SADC Agreement on Assistance in Tax Matters and the OECD-Council of Europe Multilateral
Convention on Mutual Administrative Assistance in Tax Matters

2
(ICTD, 2023). Tax treaties usually cover direct taxes on income and capital and
exclude indirect taxes.

The general objectives of tax treaties include the protection of taxpayers against
double taxation to support the flow of international trade and investment and the
transfer of technology. They also aim to prevent certain types of discrimination as
between foreign investors and local taxpayers, and to provide a reasonable element
of legal and fiscal certainty as a framework within which international operations can
confidently be carried on (UN, 2021). Tax Treaties can be essential in attracting foreign
direct investment, as corporations and taxpayers in general who operate across
borders seek to maximize global profits while at the same time incurring in the lowest
global tax liability.

The field of International Taxation does not have an overlooking regulatory or policy
guidance international body and because it is a field where policy sovereignty is
safeguarded2, countries have relied on international models for guidance on the
negotiation of these treaties, and as a means to achieving some standardization of the
sharing of taxing rights across borders.

There are currently over 3,000 bilateral income tax treaties in force globally, the
majority of which are based on the United Nations Model Double Taxation Convention
between Developed and Developing Countries (the UN MTC) and the Organisation
for Economic Co-operation and Development Model Tax Convention on Income and
on Capital (the OECD MTC). (Arnold)

The League of Nations, the predecessor of the United Nations commenced work on
the development of model tax conventions, after World War I, including models dealing
with taxes on income and capital. The product of this work was the drafting of Model
Conventions in 1943 and 1946. However, these Model Conventions were not
unanimously accepted. Two decades later the OECD took on the work and published
its first model in 1963, when it was still the Organisation for European Economic Co-
operation (OEEC) created after the World War II. In 1980 the first UN MTC was

2
States reserve the right to implement domestic laws, except where there is an international agreement which
differs from domestic provisions, in which case the international agreement prevails.

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published. ATAF published its first model in 2016, and SADC in 2013 (discussed
below).

Currently there are several models available for choosing by negotiating partners,
developed by different international organizations such as the The United Nations3 -
UN, Organisation for Economic Co-Operation and Development - OECD4, the African
Tax Administration Forum - ATAF, the Southern African Development Community –
SADC, amongst others. Each of these organizations developed models to provide
policy guidance to their member states and although these models are not legally
binding, they are a useful tool in defining a state’s international tax policy. Once the
model provisions are negotiated and agreed to, they form part of the new treaty, which
is, in turn, legally binding. Tax Treaty Models usually contain a detailed Commentary
which is an integral and important element, as it provides non-binding interpretative
regulation-like provisions to support application of each paragraph and article of the
treaty.

The choice of a model will usually depends on a wide range of considerations. Which
tax and revenue interests are to be protected by the parties, the regional or political
placement of the State Parties and their level of economic development, are some of
the factors. In the efforts of international and regional cooperation states may be
inclined to adopt clauses or articles from models of the region they are part of or those
that align with the overall international economic policy of the state. In creating a
country model, parties may (and often do) choose articles from different models, thus
creating a version that best represents their revenue protection interests.

While the models may differ in specific provisions, they all follow a similar format and
all aim to fairly distribute taxing rights between the residence state and the state of
source5 of the income, while closing base erosion gaps, without creating opportunities
for non-taxation. It is important to note that the different structures of these
organizations affect the adherence to these Models, and the type of international

3
Through the Committee of Experts on International Cooperation in Tax Matters, under the UN Economic and
Social Council (ECOSOC)
4
Through the OECD Committee on Fiscal Affairs (CFA)
5
A detailed discussion of the concepts of residence and source taxation can be found in the United Nations
Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries, 2023.

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commitment the country undertakes. The United Nations is an international
organization which has 193 of the 195 recognized world countries/jurisdictions as its
members. The OECD is an organization that supports economic cooperation and
development of its 38 member countries, mostly considered developed economies
and 22 of which are members of the European Union. ATAF is a technical cooperation
organization that supports 30 African Tax Administrations (rather than countries or
states).

At an international level, the most widely used models are the OECD MTC and UN
MTC. The OECD MTC is widely seen as favouring capital-exporting countries over
capital-importing countries (Arnold)6. The OECD MTC eliminates double taxation by
safeguarding the resident state’s right to tax income from its taxpayers and limiting
some or all of the source country’s right to tax certain types of income earned by
residents of the first state. This feature of the OECD MTC is appropriate if the flow of
trade and investment between the two countries is reasonably equal, and the
residence country taxes any income exempted by the source country. In the absence
of such balanced flow of trade and investment, the OECD MTC may not be appropriate
for treaties entered into between capital-importing and capital-exporting countries
(Arnold). The UN MTC represents a compromise between the source and residence
principles, and it generally favours retention of greater source country taxing rights,
i.e. the taxation rights of the host country of investment, as compared to those of the
country of residence the investor (UN, 2021). As a result, many developing or capital-
importing countries, which are more often on the receiving end of investment flows,
tend to devise their own model treaty following guidance from the UN MTC.

2. RECENT DEVELOPMENTS
Tax administration and policy, tend to be responsive to the revenue needs and market
behaviour. Policy makers respond to changes in the way markets operate or to
significant world events that justify a legal redirection. In the face of what we can call
a boundary-less economic environment, business became increasingly disconnected
to the previous canonical requisites for attribution of tax liability, such as residence,
physical presence and place of management, governments all over the world were

6
In this paper, as in general, the terms developed and developing countries are often used interchangeably to
the terms capital-exporting and capital-importing countries, respectively

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faced with ineffective tax laws that could not attract the expected revenue from large
corporations which would operate outside of its borders but maintain a substantial
market presence and usage to achieve its profits. Whether it be through dividend
repatriation, excessive interest deductions, the setting of shell companies in tax
havens for minimum to no tax liability or exploiting natural resources through excessive
tax benefits, corporations of all sizes were essentially eroding the tax base of
countries, increasing their profits and not leaving their fair contribution in the country
that provided the resources for such profits.

While countries attempt to overcome these identified risks through improving tax
policy, most have concluded that bilateral and multilateral efforts may be more fruitful
than unilateral/domestic law solutions and have entered the realm of tax treaty
negotiation and signing. These are the known Tax Treaties which often follow
international models, but which ultimately represent a compromise and best possible
result for all negotiating states’ interests.

Notwithstanding the efforts of multilateral cooperation through international Models,

some countries have identified the need for more firm multilateral commitments. Such
is the case of the East African Community Double Taxation Agreement, which,
different from the Models, is an agreement that is binding on all its seven East African
country parties7. This approach is to be distinguished from the SADC Model, as SADC
is a regional political organization with membership by 16 countries in Southern Africa
and its Model provides guidance for the structure and content of bilateral Double Tax
Treaties between its members or with countries outside of the region.

Another important multilateral landmark is the OECD/G20 BEPS Inclusive Framework

and its BEPS Project. In 2016 a global task force was set up by the OECD, which
identified 15 action points to address the aggressive tax planning that had been
identified (OECD, 2023). The BEPS Project Actions aimed at resolving mismatches in
tax rules that allowed taxpayers to plan aggressively and artificially shift profits to low
or no-tax jurisdictions, thus creating fictitious business structures, whether legal or
illegal. From the 15 actions, four were identified as being Minimum Standards, being

7
The Republics of Burundi, Kenya, Rwanda, Somalia, South Sudan, Uganda, and the United Republic of
Tanzania.

6
those that presented solutions to more immediately urgent concerns and which could
realistically be implemented by the 145 signatory jurisdictions to this “Inclusive
Framework” (OECD, 2023). The Minimum Standards were implemented through
ratification and domestication of existing regulations.

This was the birth of the second global wave of bilateral efforts to address the base
erosion problem (under the premise that the negotiation of Tax Treaties was the first).
BEPS Action 6 addressed the “Prevention of Tax Treaty Abuse” and provided several
recommendations for the improvement of new Tax Treaties, in ways that would
prevent treaty shopping (artificial structures with the sole purpose of catching benefits
of a treaty that would not otherwise be available to a taxpayer) and without the treaties
creating opportunities for double non-taxation.

In response to the BEPS Project, all international Tax Treaty Models underwent
revisions. The OECD’s Working Party No. 1 of the Committee on Fiscal Affairs has
conducted updates to the OECD MTC published in 1994, 1995, 1997, 1998, 2000,
2003, 2005, 2008, 2010, 2014, and 2017 (the latter followed the BEPS Project findings
and is the latest version). The then UN Ad Hoc Group of Experts in Tax Treaties
Between Developed and Developing Countries identified significant changes in the
international economic, financial and fiscal environment, and recognizing the updates
that the OECD MTC had undergone, saw the need for an ongoing review of the UN
MTC. Thereafter, versions of the UN MTC were published in 2001, 2011, 2017 and
2021 (the current version).

III. SADC DOUBLE TAX AVOIDANCE AGREEMNTS MODEL

1. BACKGROUND
The Southern African Development Community (SADC) was formed in 1980 as the
“Southern African Development Co-operation Conference” (SADCC) by nine of the
current Member States. On 17 August 1992 in Windhoek, Namibia, the SADCC was
transformed into SADC with the signing of the SADC Declaration and Treaty. SADC
currently has 16 Member States: Angola, Botswana, Comoros, Democratic Republic
of Congo, Eswatini, Lesotho, Madagascar, Malawi, Mauritius, Mozambique, Namibia,
Seychelles, South Africa, United Republic of Tanzania, Zambia and Zimbabwe. The
SADC Treaty objectives are implemented through agreements and Protocols that are

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legally binding international agreements committing the Member States. The SADC
Protocol on Finance and Investment in particular, aims to increase cooperation,
coordination and management of macroeconomic, monetary and fiscal policies and
establishment of macroeconomic stability as a precondition to sustainable economic
growth and for the creation of a monetary union in the region (SADC, SADC Protocol
on Finance and Investment, 2006). As stated in its annexes, this would be achieved
through cooperation in investment, macroeconomic convergence, cooperation in tax
and related matters, and many more.

Under Article 5 of Annex 3 of the Protocol on Finance and Investment, SADC Member
States agreed on the terms of the region’s Cooperation in Tax and Related matters,
namely that Member States would: 1 - Develop a common policy for the negotiation of
Tax Agreements among themselves or third State; 2 - Strive to ensure speedy
negotiations, ratification and implementation of Tax Agreements; 3 - Take the
necessary steps to establish amongst themselves a comprehensive network of
agreements for the avoidance of double taxation that assists the effective exchange
of information, mutual agreement procedures and co-operation amongst themselves;
4 - Develop a Model Tax Agreement for SADC that, among other things, takes account
of the particular socio-economic development needs of each State Party, with a view
to achieving a common policy for Tax Agreements; 5 - Draw up guidelines for the
effective exchange of information, the implementation of Mutual Agreement
procedures, on completion of the Model Tax Agreement referred to in paragraph 4.

In accordance with paragraph 4 of Article 5 of Annex 3 of the SADC Protocol on

Finance and Investment, the SADC Model Double Tax Avoidance Agreement (SADC
Model DTAA) was developed in 2013, inspired by the existing models at the time,
namely, the OECD MTC, the UN MTC and the African Tax Administration Forum
(ATAF) Model. The SADC Model DTAA was designed to as best as possible protect
the general needs of developing countries, specifically those of SADC Member States.
There are currently 59 Tax Treaties in force between SADC Member States, the oldest
being between South Africa and Zambia having come into force in 1956 (SADC, 2023).
The SADC Model DTAA provides policymakers with provisions which seek a balance
between securing tax revenues from priority economic sectors in the SADC region and
removing the most common tax-related barriers to Foreign Indirect Investment.

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 2. REVIEW OF THE SADC MODEL DTAA
i. REVIEW PROCESS
The Ministers of Finance and Investment of SADC Member States, through the Tax
Subcommittee, decided in 2021 to engage in the urgent task of reviewing the SADC
Model Double Tax Avoidance Agreement (SADC Model DTAA) noting that the process
should be informed by international trends to narrow differences in terms of
interpretation and aligning definitions to well established models such as the UN and
OECD models.

The review of the SADC Model DTAA comes as a part of a globally identified need to
further protect the tax base of developing countries, resource-rich countries and low-
income countries, facing the identified risks that globalisation and digitalization have
posed to revenue collection. The revised Model DTAA was envisaged to assist
Member States in the process of negotiating and re-negotiating their tax agreements
to align their agreements to internationally established standards and generate the
desired impetus for negotiations of new treaties.

The review of the SADC Model DTAA was conducted by SADC member states
themselves, as the DAC Tax Subcommittee, through its substructure (Tax Agreements
Working Group) created a Task Team for the Review of the Model DTAA, comprised
of members from Botswana, Lesotho, Mauritius, Namibia, United Republic of
Tanzania, and Zimbabwe. The review process was concluded in May 2023 with the
revision and update of the Commentaries and Reservations to the new SADC Model
DTAA.

ii. SPECIFIC CHANGES AND CONSIDERATIONS

The review of the SADC Model DTAA was based on global developments and the
resulting need for SADC Member States to negotiate and renegotiate tax agreements
that protect tax bases and prevent profit shifting in a more effective way and respond
to new business models emerging within the digital economy. SADC Member States
sought to speak in a unified voice and provide a policy instrument that best represents
the needs of the region, considering existing models and policy alternatives. The result
was a Model DTAA that is a combination of the different available DTAA models, as
well as innovative provisions that speak directly to the specificities of the SADC region.

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Specific changes made to the SADC Model DTAA:

Article 3: The “Definitions” article was reviewed to align to changes made

throughout the SADC Model DTAA. After discussions, the Task Team saw to
exclude the term “business” and “enterprise”. The commentary to Article 3 of
the SADC Model DTAA was aligned to these changes.

Article 4: Before being reviewed, paragraph 1 of Article 4 “Resident” of the

SADC Model DTAA provided Options A and B. Since then, article 4 ‘Resident’
was reviewed by the Task Team to provide further clarity to SADC Member
States on the definition of a resident for purposes of this Model. Option A has
been adopted upon the review of the Model, and Commentaries were adjusted
to provide guidance to Option under Paragraph 1 of Article 4.

Paragraph 2 (now paragraph 3) of the SADC Model DTAA was also changed,
with the removal of the last sentence, which further provides legal certainty and
reduced ambiguity in the interpretation of the article.

Article 5: The “Permanent Establishment” article was reviewed by the Task

Team in alignment with BEPS recommendations.

Subparagraph c) of paragraph 3 was removed from the SADC Model DTAA

and in the commentary to this subparagraph, references to service permanent
establishment and to Independent Personal Services were removed in line with
the changes to the Model text of Article 5, subparagraph (c).

The new subparagraph c) of paragraph 3 was in the SADC Model as

subparagraph d), and since the review it includes references to maintenance or
installation and equipment or machinery. The two italics words were already in
an alternative paragraph in the Model which was in brackets.

Subparagraphs 4.1 and 5 of Article 5 were aligned to the UN MTC and now
complies with the BEPS Minimum Standards. Commentaries were aligned to
follow.

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Article 7: “Business Profits” was reviewed by the SADC Model DTAA and is
now in line with the UN MTC, allowing for the sharing of taxing rights by the
residence state to the source state when the income is derived by or in
connection to a permanent establishment in the source state. As such,
reference was made to the UN MTC Commentary.

Article 8: “International Transport” was reviewed to provide sharing of taxing

rights for income of an enterprise of a Contracting State from the operation of
ships, rail or road transport vehicles in international traffic. Commentary was
added to support interpretation of this article.

Article 10: “Dividends” was adjusted by adopting paragraph 6 which was

already in the text in brackets, and which was inspired by the East African
Community Model Tax Convention.

Article 11: “Interest” was reviewed briefly by removing the last sentence of
paragraph 3 referring to charges for late payments being outside of the scope
of the definition of interest for purposes of this Model (thus removing the
exclusion).

Article 12: “Royalties” in its paragraph 3 was adjusted into subparagraphs to

provide a clearer reading and to include items of income from “sound recording
or any other like medium”, “any computer programme or software” and to
remove reference to “radio or television broadcasting”.

Article 12A: The article on “Fess for Technical Services” was previously article
13 and has since been renumbered to 12A in alignment with the UN MTC.

Article 12B: “Income from Automated Digital Services” was introduced into the
SADC Model DTAA in alignment with the UN MTC. The commentary to the new
Article 12B of the SADC Model DTAA was introduced.

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Article 13:“Capital Gains”, the shareholding requirement in paragraph 4 was
removed, thus making the sharing of the taxing rights applicable directly.

Paragraph 5, which gave a sole taxing right to the residence state for other
gains not mentioned in paragraph 4, was removed.

Paragraph 7 was added to provide for the complete opposite principle (a

sharing of the taxing right for gains not mentioned in the other paragraphs).

Article 14: “Independent Personal Services” was included in line with the UN
MTC. Commentary was added to support the interpretation of the new article.

Article 17: The article on “Entertainers and Sportspersons” had the inclusion of
paragraph 3 referring to include an exemption in the state of source for state
funded activities or under cultural agreements between governments.

Article 18: The revised Article 18 has been renamed to “Pensions and Social
Security Payments” and it now follows Alternative B of the UN MTC and
Commentaries are to follow the latter Model Commentaries.

Article 20: The revised Article 20 has been renamed to “Students”, in alignment
to the OECD MTC and supporting Commentaries also follow the UN MTC
Commentaries.

Article 20A: This article, previously number 21 on “Professors and Teachers”

was renumbered to 20A in alignment with the UN MTC, and supporting
Commentaries also follow the UN MTC Commentaries.

Article 22: The new Article 22 “Miscellaneous Rules Applicable to Certain

Offshore Activities” was added to the SADC Model DTAA upon its revision, and
is a unique addition, specific to this Model. Supporting Commentary has been
drafted by the SADC Tax Agreement Task Team.

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 Article 23: No changes were made to Article 23 “Elimination of Double
Taxation”, but the Commentary was clarified and aligned to the recent OECD
MTC Commentary.

Article 24: Commentary to Article 24 “Non-Discrimination” was clarified and

aligned to the changes made throughout the SADC Model and align to the
OECD MTC and UN MTC Commentary wherever applicable.

Article 25: The article on “Mutual Agreement Procedure” was slightly adjusted
in paragraph 1 to allow taxpayers to present a case to either competent
authority, rather than solely to the one of their countries of residence.

Paragraph 5 was removed, thus eliminating the reference to the arbitration

process. Commentaries were aligned.

Article 29: The new Article 29 “Entitlement to Benefits” was added to the SADC
Model DTAA upon its revision, and it is aligned to the UN MTC. Commentary
was added to support the interpretation.

iii. SUMMARY OF THE KEY CHANGES TO THE SADC MODEL

DTAA AND COMMENTARY
In general, changes to the SADC Model DTAA were in alignment with the Base
Erosion and Profit Shifting (BEPS) minimum standards recommendations, to cover
other tax policy positions preferred by Member States through the Task Team and
adjustment of the references to the OECD MTC the UN MTC, to follow their latest
versions (2017 and 2021, respectively). The Commentary to the SADC Model DTAA
were adjusted to match the cross-references of the revised SADC Model DTAA and
provide adequate interpretation support.

The Commentary to the SADC Model DTAA begins with an introductory section
‘Overview’. This section provides a summary of the contextual approach taken in the
review of the SADC Model DTAA and the international tax circumstances that
surrounded the changes hereto made, especially by referencing the latest versions of
the international models, namely the 2017 the OECD MTC and the 2021 the UN MTC.

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 IV. CONCLUSION
Tax Treaties are an important tool for the definition of a State’s international tax policy,
can be decisive in attracting foreign direct investment and play a valuable diplomatic
role in the relationships with other States. Over the decades international bodies have
developed models, which albeit non-binding, serve as guides for the negotiation of
such treaties. Some of the more widely used models are those created by the OECD
and the UN. There are other more region-specific models such as that created by
ATAF and SADC. The choice of Models is a domestic policy decision which will
influence the result of negotiations and the treaty obtained.

The SADC Model DTAA was designed in 2013 to address more specific needs of its
Member States and like all international tax models, in 2023 SADC reviewed its model
following global tax policy needs. The review process was conducted by SADC
Member States through a support program and under the auspices of the SADC Tax
Subcommittee and the Committee of Ministers of Finance and Investment, The review
was aimed to account for significant regional and international developments in
international tax, especially base erosion concerns and measures brought by the
OECD BEPS Project. The reviewed SADC Model DTAA also brings provisions that
are unique and respond to specific needs identified by tax experts of the region. The
designing and review of a SADC Model DTAA follows the agreements made by SADC
Member States under Annex 3 of the Protocol of Finance and Investment, in their
efforts to further regional cooperation in tax and related matters.

The paper travels through the historical developments that led to the current state of
the international tax scene and the importance of Tax Treaty models, and especially
covers the changes made to the SADC Model DTAA. As prescribed under the SADC
Protocol on Finance and Investment, SADC Member States strive to cooperate and
integrate in matters and coordinate the tax regimes of the region and are determined
to take the necessary steps to maximize such cooperation. Thus, the SADC Model
DTAA is a response to this call by Member States and is now equipped to protect their
identified revenue protection needs and is available for use by all SADC Member
States and any other interested states.

Author: Elisângela Rita (PO Fiscal Policies, Finance Investment and Customs, SADC)

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BIBLIOGRAPHY
Arnold, B. J. (n.d.). An Introduction to Tax Treaties.
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SADC. (2006). SADC Protocol on Finance and Investment. (p. 42). Maseru: SADC.
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