Cookies Policy

This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies.

I accept this policy

Find out more here

The Dominant Voices in Double Taxation Agreements: A Critical Analysis of the “Dividend” Article in the Agreement between Uganda and the Netherlands

No metrics data to plot.
The attempt to load metrics for this article has failed.
The attempt to plot a graph for these metrics has failed.
The full text of this article is not currently available.

Brill’s MyBook program is exclusively available on BrillOnline Books and Journals. Students and scholars affiliated with an institution that has purchased a Brill E-Book on the BrillOnline platform automatically have access to the MyBook option for the title(s) acquired by the Library. Brill MyBook is a print-on-demand paperback copy which is sold at a favorably uniform low price.

Access this article

+ Tax (if applicable)
Add to Favorites
You must be logged in to use this functionality

In a bid to attract foreign investment, Third World countries are increasingly concluding Double Taxation Treaties with capital-rich countries, based on either the UN model treaty convention or the OECD model. Using the example of the dividend Article in the Uganda-Netherlands treaty, the discussion in this article illustrates the increased use of tax treaties to shift income from developing to developed countries. By essentially reducing the tax rate on dividend income to nil, that treaty significantly erodes Uganda's tax base. Such agreements raise concern, especially when one takes into account the fact that investment decisions are often driven by factors external to tax, meaning that reduced tax rates do not guarantee increased investments. Worse still, because developing countries are net capital importers, the benefits accruing from such treaties are often one-sided. The paper calls for a rethinking and redrafting of the UN model convention to ensure that the taxing rights of Third World countries are strengthened. In addition, since the practical reality is that developed countries often base their agreements (even with developing countries) on the OECD model, there is a need to amend the latter model to take this reality into account.

Affiliations: 1: Ph.D. Candidate, Faculty of Law, University of British Columbia, Canada


Full text loading...


Data & Media loading...

Article metrics loading...



Can't access your account?
  • Tools

  • Add to Favorites
  • Printable version
  • Email this page
  • Subscribe to ToC alert
  • Get permissions
  • Recommend to your library

    You must fill out fields marked with: *

    Librarian details
    Your details
    Why are you recommending this title?
    Select reason:
    International Community Law Review — Recommend this title to your library
  • Export citations
  • Key

  • Full access
  • Open Access
  • Partial/No accessInformation