New analysis of the @actionaid tax treaties dataset reveals a growing divide between the treaties developing countries sign among themselves (which are becoming more source-based, leaving more taxing rights intact), and those they sign with EU countries (which are not). Thread. 
The UN model treaty, designed for use in treaties between developed and developing countries, is not becoming more common in EU-developing country treaties, but it is among developing countries.
The difference is most stark for permanent establishment (PE), where treaties among developing countries are becoming much more source-based.
The difference applies across a wide range of elements within the PE definition, but it is somewhat hidden because there is no difference for the most commonly discussed area, the length of time for a construction site to constitute a PE.
Little difference in the average withholding tax rates between the two groups, which are declining across the board. But the non-OECD group shows a wider variation: the lowest rates across the board are found in treaties with Gulf states, Mauritius & China, not with EU members.
There is much variation in the overall balance of tax treaties both between EU member states and within many of their existing treaties.
For example, on the touchstone issue of withholding taxes on technical service fees, there's wide variation between EU members. The UK, which now does not accept this in new treaties, has the largest number left over in its older treaties.
Looking at withholding tax rates shows Ireland as a real anomaly (data for treaties as at 1/1/2015, some have been renegotiated since). Ends.
I should mention, all of this was for a presentation at the @EU_Taxud seminar for tax treaty negotiators currently underway in Montenegro.
unroll please
