Double taxation agreements are instruments of revenue allocation as much as relief. Each clause quietly decides which of two states keeps the right to tax a flow of income, and a treaty that reads as benign can, on inspection, surrender a developing economy’s base to conduit structures and aggressive planning.
This explorer guides an official through a treaty article by article, flags the provisions that most often leak revenue, and benchmarks each one against both the United Nations / ATAF approach, which protects the taxing rights of the capital-importing source state, and the OECD approach, which leans toward the residence state. Two live examples are pre-loaded so the findings can be read immediately; a blank template lets you assess any other treaty and generate a report.
Each indicator is rated from the perspective of the source state protecting its tax base: green meets the protective benchmark, amber is a partial or contestable provision, red is a recognised leakage channel. Indicators carry weights reflecting their revenue significance (for example the anti-abuse rule and the technical-fees article weigh more heavily than the students article). The headline figure is a weighted risk percentage, banded as Lower (0–33), Elevated (34–60) and High (61–100). It is a structured screening aid to direct attention and inform renegotiation priorities, not a substitute for full legal analysis, treaty-by-treaty modelling of revenue at stake, or the wider political economy of the bilateral relationship.