EFFECTIVENESS OF INTERNATIONAL DOUBLE TAXATION AVOIDANCE TREATIES

Rafiyeva Zarina Xusanovna

Authors

Rafiyeva Zarina Xusanovna Assistant teacher of the department “Investments and innovations”

Keywords:

double taxation, tax treaties, Uzbekistan tax system, OECD Model Convention, foreign direct investment, tax avoidance, BEPS, fiscal policy, international taxation, tax administration efficiency.

Abstract

This study analyzes the effectiveness of international Double Taxation Avoidance Agreements in the context of Uzbekistan. It examines legal, economic, and institutional dimensions of tax treaties, focusing on their role in eliminating double taxation, attracting foreign direct investment, and improving tax administration efficiency. The findings indicate that Double Taxation Avoidance Agreements significantly enhance investment inflows and legal certainty, while also supporting structural modernization of the tax system.

References

OECD. (2017–2023). OECD Model Tax Convention on Income and on Capital. OECD Publishing, Paris.

OECD. (2021). Addressing Base Erosion and Profit Shifting (BEPS): Action Plan Reports. OECD Publishing.

United Nations. (2017). United Nations Model Double Taxation Convention between Developed and Developing Countries. UN Department of Economic and Social Affairs.

International Monetary Fund (IMF). (2024). Uzbekistan: Selected Issues and Country Report. Washington, DC.

World Bank. (2023–2025). Uzbekistan Economic Update: Fiscal Policy and Investment Climate Analysis. Washington, DC.

Tax Code of the Republic of Uzbekistan. (2026). Official consolidated version with amendments.

State Tax Committee of the Republic of Uzbekistan. (2024–2025). Annual Tax Administration and Compliance Reports.

PwC. (2025). Uzbekistan Tax Summaries: Corporate Taxation and International Tax Rules. PricewaterhouseCoopers Global Tax Network.

EY. (2026). Uzbekistan Tax Alerts: Key Amendments to the Tax Code Effective 2026. Ernst & Young Global Limited.

Keen, M., & Konrad, K. A. (2013). The Theory of International Tax Competition and Coordination. Handbook of Public Economics.

Blonigen, B. A., & Davies, R. B. (2004). “The Effects of Bilateral Tax Treaties on U.S. FDI Activity.” International Tax and Public Finance, 11(6), 601–622.

Egger, P., Larch, M., Pfaffermayr, M., & Winner, H. (2006). “The Impact of Endogenous Tax Treaties on Foreign Direct Investment.” Journal of International Economics, 68(2), 369–385.

Avi-Yonah, R. S. (2007). International Tax as International Law. Cambridge University Press.

HM Revenue & Customs (UK). (2023). Double Taxation Relief Manual and Treaty Network Guidance.