Tax treaties: country ratings summary

European Parliament
The European Parliament has recognised the potential negative impacts of tax treaties on developing countries and called for tax treaties between EU countries and developing countries to be negotiated in a way that ensures policy coherence for development and fairness for developing countries.
European Commission
The European Commission has recognised that tax treaties can have negative impacts on developing countries. However, the Commission has not yet proposed any concrete actions that can adequately address this problem.
Austria
Although the number of Austrian treaties with developing countries is slightly below average, the average rate of reduction of developing country tax rates imposed through those treaties is significantly above average, which indicates that these treaties could have substantial negative impacts on developing countries.
Belgium
Belgium has a relatively high number of tax treaties with developing countries, but the average reduction of tax rates imposed through those treaties is low. However, what the average does not show is that several of Belgium’s tax treaties with developing countries are ‘very restrictive’, and therefore give particular cause for concern.
Czech Republik
Compared to the other countries covered by this report, the number of tax treaties between the Czech Republic and developing countries, as well as the reduction of tax rates imposed by those treaties, are both above average.
Denmark
Denmark has relatively few tax treaties with developing countries, and the average reduction of tax rates imposed through those treaties is low. However, what the average does not show is that several of Denmark’s tax treaties with developing countries are ‘very restrictive’, and therefore give particular cause for concern.
Finland
Although not unproblematic, Finland’s tax treaties with developing countries give fewer reasons for concern compared to many other countries covered by this report, since Finland’s number of treaties with developing countries, as well as the average reduction of tax rates imposed through those treaties, are both below average.
Germany
Germany’s tax treaties with developing countries are a cause of concern due to the high number of ‘very restrictive’ treaties. Also of concern is the fact that Germany’s total number of treaties with developing countries, as well as the average reduction of tax rates through those treaties, are both above average among the countries covered by this report.
Hungary
Although not unproblematic, the Hungarian tax treaty network gives fewer reasons for concern compared with many other countries covered by this report, since Hungary’s number of treaties with developing countries, as well as the average reduction of developing country tax rates, are both significantly below average among the countries covered by this report.
Ireland
Of all the countries covered by this report, the Irish tax treaties with developing countries introduce the highest average reductions on the tax rates of their developing country treaty partners. Furthermore, three of Ireland’s treaties with developing countries are ‘very restrictive’ treaties. The number of tax treaties between Ireland and developing countries is below average. However, Ireland is currently planning to expand its number of treaties with developing countries.
Italy
Italian tax treaties with developing countries, on average, reduce the tax rates less than most other countries covered in this report. However, what the average does not show is that Italy has the highest number of ’very restrictive’ tax treaties with developing countries among all the countries covered by this report.
Latvia
Although Latvia has relatively few tax treaties with developing countries, these treaties have a relatively high negative impact on the developing countries that have signed them. This is because Latvia’s tax treaties, on average, impose relatively high reductions of developing country tax rates.
Luxembourg
Although not unproblematic, the Luxembourg tax treaty network gives fewer reasons for concern compared with many other countries covered by this report, since Luxembourg’s number of treaties with developing countries, as well as the average reduction of developing country tax rates, are both significantly below average among the countries covered by this report.
The Netherlands
The Netherlands has a high number of ‘very restrictive’ tax treaties with developing countries. Furthermore, compared to the other countries covered by this report, the number of tax treaties between the Netherlands and developing countries, as well as the reduction of tax rates imposed by those treaties, are both above average.
Norway
Norwegian tax treaties with developing countries, on average, reduce the tax rates less than most other countries covered in this report. However, what the average does not show is that Norway has a significant number of ‘very restrictive’ tax treaties with developing countries.
Poland
Polish tax treaties with developing countries, on average, introduce quite limited reductions of developing country tax rates. However, what the average does not show is that Poland has a significant number of ‘very restrictive’ tax treaties with developing countries.
Slovenia
Although Slovenia’s number of treaties with developing countries is the lowest among all countries covered by this report, the average rate of reduction of developing country tax rates through those treaties is above average, and thus Slovenia’s tax treaties can have negative impacts on developing countries.
Spain
Among all the countries covered by this report, Spain has on average been the second most aggressive negotiator when it comes to lowering developing country tax rates through tax treaties. Spain also has a relatively high number of tax treaties with developing countries, which makes the situation even more concerning.
Sweden
Sweden has several ‘very restrictive’ tax treaties with developing countries. Furthermore, compared to the other countries covered by this report, the number of tax treaties between Sweden and developing countries, as well as the reduction of tax rates imposed by those treaties, are both above average.
United Kingdom
The UK has a high number of ‘very restrictive’ tax treaties with developing countries. Furthermore, on average, the UK’s tax treaties with developing countries contain relatively high reductions in developing country tax rates. The fact that the UK at the same time has the highest number of treaties with developing countries gives even more reason for concern.

DOWNLOAD REPORT