Abstract
This chapter provides an overview of the non-discrimination obligations in the multilateral General Agreement on Trade in Services (GATS), including national treatment and most favoured nation treatment and examines how the GATS non-discrimination obligations interrelate with the Organization for Economic Co-operation and Development (OECD) and UN Model Tax Treaties. The purpose of the discussion in this chapter is twofold. The first is to make plain the differences in non-discrimination principles that emerge in tax and trade agreements as they apply to non-resident services and service providers. The second is to illustrate the permitted differences in the tax treatment of non-resident service providers under the GATS due to the carve out of tax measures from trade obligations.
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Notes
- 1.
- 2.
The OECD and UN Model Treaty non-discrimination obligations are viewed as integral to the study as these are the provisions upon which most bilateral tax treaties are based.
- 3.
As of July 14, 2016 this number has now expanded to 163 Member governments accounting for over 90% of the world’s trade. WTO (2016), online: WTO https://www.wto.org/english/thewto_e/whatis_e/tif_e/org6_e.htm.
- 4.
Further negotiations unfortunately ground to a halt in the Doha Round. A number of countries including Canada, the United States, Mexico, Switzerland, Japan, Korea, Hong Kong, Australia, and the European Union are negotiating a new international instrument to further liberalize trade in services. The instrument will be called the Trade in Services Agreement (TISA). Parties to the negotiations are responsible for some 70% of global services trade. The TISA negotiations were borne out of the frustration felt by certain WTO Members when negotiations to liberalize services trade became a casualty of the stalled Doha Round of WTO negotiations. The TISA is to be negotiated outside of the WTO by a subset of WTO Members committed to services trade liberalization. Expectations for the TISA are that it will reflect new types of services that have emerged since the WTO’s GATS (1995) was negotiated some 20 years ago, lock-in liberalization undertaken unilaterally by parties since the GATS came into force, and expand commitments among the parties on market access and non-discrimination.
- 5.
The GATS, Article XVII.
- 6.
See Broadman (1993).
- 7.
The GATS.
- 8.
The GATS Article I at para 2.
- 9.
WTO (1997b), WTO Doc WT/DS27/R/USA at para 7.285 [EC Bananas Panel Report] defined the scope of application of the in the following terms: “[N]o measures are excluded a priori from the scope of the GATS as defined by its provisions. The scope of the GATS encompasses any measure of a Member to the extent it affects the supply of a service regardless of whether such measure directly governs the supply of a service or whether it regulates other matters but nevertheless affects trade in services.” The Appellate Body upheld this finding and held that no provision of the Agreement “suggest[s] a limited scope of application for the GATS.” WTO (1997a), WTO Doc WT/DS27/AB/R at para 220 [EC Bananas Appellate Body Report].
- 10.
The Appellate Body, ibid also made the following comment: “[t]his Agreement applies to measures by Members affecting trade in services. In our view, the use of the term ‘affecting’ reflects the intent of the drafters to give a broad reach to the GATS. The ordinary meaning of the word ‘affecting’ implies a measure that has ‘an effect on’, which indicates a broad scope of application.”
- 11.
The GATS, Article XXVIII(a): In WTO (2000), WTO Doc WT/DSI39/AB/R at paras 151–152 and 155 [Auto Industry Appellate Body Report] the Appellate Body held that whether a measure “affects” trade in services must be assessed before any further consistency of a measure with other GATS provisions is considered.
- 12.
The GATS, Article XXVIII(b): the “supply of service” includes, but is not limited to the “production, distribution, marketing, sale and delivery of a service.”
- 13.
The GATS, Article XX.
- 14.
The wording “treatment no less favourable” in the GATS Article II(1) has been interpreted broadly by the WTO Appellate Body to include both de facto as well as “de jure discrimination.” See the Auto Industry Appellate Body Report at para 234.
- 15.
Members were allowed to seek such exemptions before the Agreement was entered into force. New exemptions can only be granted to new Members at the time of accession or, in the case of current Members, by way of a waiver under Article IX(3) of the WTO Agreement. All exemptions are subject to review, and should in principle not last longer than 10 years. Further, the GATS allows groups of Members to enter into economic integration agreements or to mutually recognize regulatory standards, certificates and the like if certain conditions are met.
- 16.
See Schedules to the GATS to view a specific country’s schedules. For Canada see WTO (1994a) WTO Doc GATS/EU16, online WTO http://docsonline.wto.org. Canada has claimed exemptions for film, video and television co-production, with respect to fishing, banking, trust and insurance services, air and marine transport, and for certain services related to agriculture.
- 17.
Further, market access commitments may be made subject to various types of limitations that are enumerated in Article XVI(2). For example, limitations may be imposed on the number of services suppliers, service operations or employees in the sector, the value of transactions, the legal form of the service supplier, or the participation of foreign capital.
- 18.
The GATS, Article XVII provides that “each Member shall accord to services and service suppliers of any other Member, in respect of all measures affecting the supply of services, treatment no less favourable than that it accords to its own like services and service suppliers.” The GATS limits the application of this standard to those sectors specified in each Member’s Schedule of Concessions, and allows Members to set forth any applicable conditions.
- 19.
The existence of specific commitments triggers further obligations concerning, inter alia, the notification of new measures that have a significant impact on trade (GATS Article III) and the avoidance of restrictions on international payments and transfers (GATS Article XI).
- 20.
See Cossy (2006).
- 21.
See the GATS Article XVII.
- 22.
See the WTO (1994b), WTO Doc GATS/SC/90, online WTO http://docsonline.wto.org at 9–10, setting forth limitations on national treatment for foreign employee benefit trusts and excise taxes on transfers to foreign entities. See Lang and Stack (2000) at 566–581.
- 23.
A quick review of the schedules reveals that many countries, including Canada, the US and Mexico, have claimed most favoured nation exemptions with respect to tax provisions. See for example WTO (1994a) at para 3 detailing the exemption from taxes on income of non-residents from international transport on the basis of reciprocity with the resident country. The US has also listed tax measures relating to favourable treatment for Mexican and Canadian residents, the Caribbean Basin Initiative, international transport income (including aircraft and rolling stock) derived by residents of countries with reciprocal measures, earnings from communication satellites and denials of deductions for residents of countries participating in international boycotts or maintaining discriminatory tax regimes. WTO (1994a).
- 24.
See WTO (1994b).
- 25.
Ibid under Part I Horizontal Commitments.
- 26.
Farrell (2013) at Chapter 8.3.1.
- 27.
See WTO, Schedules of Commitments and Lists of Article II Exemptions, online: WTO http://www.wto.org/english/tratop_e/serv_e/serv_commitments_e.htm.
- 28.
Subject to the requirement that such measures are not applied in a manner which would constitute a means of arbitrary or unjustifiable discrimination between countries where like conditions prevail, or a disguised restriction on trade in services.
- 29.
As discussed, the potential for discrimination in direct tax matters became a major issue in the final days of negotiating the WTO Agreement in the Uruguay Round. The US strongly opposed the inclusion of direct taxes in the national treatment requirements under the GATS. See Stahl (1994).
- 30.
Direct taxes are defined in the GATS Article XXVIII(o) as “all taxes on total income, on total capital or on elements of income or of capital, including taxes on gains from the alienation of property, taxes on estates, inheritances and gifts, and taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.”
- 31.
Specifically, the footnote to the GATS Article (XIV) refers to the following activities: “Measures that are aimed at ensuring the equitable or effective imposition or collection of direct taxes include measures taken by a Member under its taxation system which:
-
apply to non-resident service suppliers in recognition of the fact that the tax obligation of non-residents is determined with respect to taxable items sourced or located in the Member’s territory; or
-
apply to non-residents in order to ensure the imposition or collection of taxes in the Member’s territory; or
-
apply to non-residents or residents in order to prevent the avoidance or evasion of taxes, including compliance measures; or
-
apply to consumers of services supplied in or from the territory of another Member in order to ensure the imposition or collection of taxes on such consumers derived from sources in the Member’s territory; or
-
distinguish service suppliers subject to tax on worldwide taxable items from other service suppliers, in recognition of the difference in the nature of the tax base between them; or
-
determine, allocate or apportion income, profit, gain, loss, deduction or credit of resident persons or branches, or between related persons or branches of the same person, in order to safeguard the Member’s tax base.
Tax terms or concepts in the GATS Article XIV(d) and in the footnote are determined according to tax definitions and concepts, or equivalent or similar definitions and concepts, under the domestic law of the Member taking the measure.”
-
- 32.
The GATS Article XIV(d).
- 33.
Note however, that no justification is required under Article XIV unless the national treatment obligation is otherwise violated. To establish such a violation three conditions must be met; first the non-resident service provider must be ‘like’ a national service provider, second, the difference in treatment must be based on the national origin of the service or service provider and third the treatment accorded to the non-resident must be less favourable than that accorded to a resident national. See WTO (1 December, 1993).
- 34.
The GATS, Article XXII(3). This will serve to prevent debate about a Member government’s right to exercise wide powers under its domestic law to both safeguard the tax base and to define its scope.
- 35.
The GATS, Article XXII(3).
- 36.
See OECD (2014), Commentary to Article 25, para 44.1.
- 37.
The OECD and UN Model Tax Treaties both include a non-discrimination article. See 24(3). In order to avoid doubt some tax treaties have clarified the role of the GATS.
- 38.
See for example Article XXV of the Canada-US Tax Treaty.
- 39.
A footnote to Article XXII(3) provides that if there is a disagreement about whether the matter falls within the scope of a tax treaty and the tax treaty was in existence at the time the WTO Agreement entered into force, one country cannot unilaterally challenge the issue of the tax treaty’s scope under WTO procedures. Both parties to the existing tax treaty must consent if the WTO dispute resolution procedure (rather than a tax treaty procedure) is to be engaged. However, if future tax treaties are silent on the issue, either treaty partner may unilaterally apply to determine whether a matter falls within the scope of a tax treaty before the WTO’s Council for Trade in Services, which may then refer the matter to binding arbitration.
- 40.
Canada-US Tax Treaty, Article XXIX.
- 41.
See the discussion in Chap. 3 at Sect. 3.2.3.4.
- 42.
As will be discussed below, the most favourable non-discrimination obligation under a tax treaty for a non-resident arises in circumstances where the non-resident provides services to a tax treaty partner through a permanent establishment, although even that obligation is very limited. See discussion in Chap. 3 at Sect. 3.2.3.3.1.
- 43.
Some assistance in resolving the distinction between these Tax Treaty articles can be found in the Commentary to the OECD Model Tax Treaty.
- 44.
“Business profits,” a term undefined in the OECD Model Tax Treaty and most tax treaties, are not taxable in the host country unless the enterprise carries on business in that country through a permanent establishment. The OECD Model Tax Treaty provides that business profits do not include income dealt with separately in other treaty articles. Thus business profits would generally include amounts not specifically covered in the personal service income articles.
- 45.
In the past, a blurring has occurred between business profits, royalty income and income from personal services. The problem has been distinguishing a payment in respect of management or technical service fees, which may be exempt as business profit under the OECD Model Tax Treaty Article 7, or the OECD Model Tax Treaty Article 14 (Independent Personal Services), from a royalty for the transfer of know how, which is potentially subject to a withholding tax under the royalty provisions.
- 46.
OECD Model Tax Treaty, Article 21.
- 47.
See discussion in Chap. 6 at Sect. 6.2.
- 48.
See e.g. Article 19 of the Convention between the Government of Canada and the Government of the United Mexican States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, 12 September 2001 (entered into force 12 April 2007) [Mexico–Canada Tax Treaty].
- 49.
Ibid, Article 17.
- 50.
Ibid, Article 20.
- 51.
Ibid.
- 52.
Article 14 (Independent Personal Services) was deleted from the OECD Model Tax Treaty on April 29, 2000, on the basis of the report OECD, Issues Related to Article 14 of the OECD Model Tax Convention, Issues in International Taxation, No 7 (2000) which was adopted by the Committee on Fiscal Affairs on January 27, 2000. According to the OECD Commentary at that time there were no intended differences between the concepts of permanent establishment, as used in Article 7, and fixed base, as used in Article 14, or between how profits were computed and tax was calculated according to which of Article 7 or 14 applied. It was also thought it was unclear which activities fell within Article 14 as opposed to Article 7. The result of the deletion of Article 14 is that income derived from professional services on other activities of an independent character is now governed by Article 7 as business profits under the OECD Model Tax Treaty.
- 53.
According to the OECD Commentaries, a general principle to be observed in determining whether a permanent establishment exists is that the place of business must be “fixed” in the sense that a particular building or physical location is used by the enterprise for the conduct of its business, and that it must be foreseeable that the enterprise’s use of this building or other physical location will be more than temporary; OECD (2014), Commentary on Article 5 at paras 4–8.
- 54.
Ibid at Article 5(2), para 12.
- 55.
A third deeming rule in Article 5 provides that “an enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.”
- 56.
United Nations (2013), Article 5(7).
- 57.
Other differences under the UN Model Tax Treaty that may affect whether a permanent establishment is found include the omission of the word delivery from Article 5 paragraph 4 with the result that delivery activities are not treated as ancillary and the expansion of the deeming rule with respect to when dependent agents will create a permanent establishment—to include cases where a dependent agent regularly maintains a stock and makes deliveries from it.
- 58.
United Nations (2013), Article 5(3)(b). A deemed service permanent establishment will exist in these circumstances even if an enterprise has no fixed place of business in the taxing state as required under Article 5(1). See the Revision of the Manual for the Negotiation of Bilateral Tax Treaties, UN Committee of Experts on International Cooperation in Tax Matters, 7th Sess, UN Doc E/C.18/2011/CRP.2/Add.1 (Geneva: 24–28 October, 2011) at 12.
- 59.
This has been the subject of discussion by the OECD and the following revisions were released in the Draft Commentary in October 2011: “Whilst the practices followed by Member countries have not been consistent in so far as time requirements are concerned, experience has shown that permanent establishments normally have not been considered to exist in situations where a business had been carried on in a country through a place of business that was maintained for less than six months (conversely, practice shows that there were many cases where a permanent establishment has been considered to exist where the place of business was maintained for a period longer than six months).” It would appear therefore, that even if the provision exceeds six months that will not necessarily lead to a permanent establishment if the tax treaty does not include a time test.
- 60.
These activities are limited to those mentioned in Article 5(4) of the OECD Model Tax Treaty which, if performed through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.
- 61.
In Article 14 of the OECD Model Tax Treaty, the term “professional services” included especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants.
- 62.
The OECD (2008) [2008 OECD Commentary] on Article 14 at para 10 indicates that reference may be made to the computational rules in Article 7.
- 63.
If the non-resident service provider is subject to tax under the business profits article, the applicable non-discrimination article provides that the source State cannot levy tax less favourably than that levied on a domestic enterprise carrying on the same activities. See Article 24(4) of the OECD Model Tax Treaty.
- 64.
Depending on the context, the non-discrimination principles found in trade agreements may apply to determine if the host country is guilty of discrimination in the area of taxation.
- 65.
The obligation applies to taxes of every kind and description (that is, to all direct and indirect taxes) levied by, or on behalf of, the State, its political subdivisions or local authorities. OECD Model Tax Treaty Article 24(6).
- 66.
The 2014 OECD Commentary confirms that Article 24 cannot be interpreted to require most favoured nation and should not be unduly extended to encompass indirect discrimination, e.g. discrimination that occurs where a provision of law indirectly favours residents over non-residents. OECD (2014), Commentary on Article 24 at para 2.
- 67.
The 2014 OECD Commentary clarifies that discrimination can only arise when all factors are equal and the different treatment is solely based on the difference that is prohibited by the relevant provision. OECD (2014), Commentary on Article 24 at para 1.
- 68.
See the definition of ‘national’ in the OECD Model Tax Treaty Article 3(1)(g), which includes a corporation.
- 69.
See the OECD Model Tax Treaty Articles 7(2) and 24(4).
- 70.
- 71.
The tax treatment of profits distributed to a permanent establishment has been a matter of recent controversy, particularly when shares form part of the holdings of the permanent establishment and are effectively connected with its activity. Member States disagree about whether the special rules that exist for the taxation of dividends distributed between companies should be extended to permanent establishments in these circumstances. See OECD (2014), Commentary on Article 24 at para 50.
- 72.
OECD (2014), Commentary on Article 24 at para 34; United Nations (2013) at para 2, which quotes para 34 of the OECD Model Tax Convention.
- 73.
Under the various provisions of the article, discrimination can only arise when all factors are equal and the different treatment is solely based on the difference that is prohibited by the relevant provision. Commentary to the article also clarifies that what is expressly mandated or authorized by other provisions of the Treaty cannot constitute a violation of the provisions of Article 24.
- 74.
This means differences in withholding taxes on dividend and interest income, for example, paid to a non-resident as compared to a resident are not considered discriminatory under the OECD or UN Model Tax Treaties. Non-resident investors are protected from discriminatory tax treatment only in so far as a maximum is set on withholding tax under other provisions in the OECD Model Tax Treaty. This more limited non-discrimination obligation is generally justified on the basis that withholding at source is necessary to ensure revenue collection. Withholding is also based on gross, not net, income. No attempt is made to rationalize gross taxation with the effective tax rates imposed on residents, a reality that is often loosely justified based on the practical difficulties of finding an accurate comparison. This issue is discussed further in Chap. 7 at Sect. 7.2.
- 75.
OECD (2014), Article 24 and Commentary on Article 24 at para 75. “[Article 24(4)] does not prohibit additional information requirements from being imposed with respect to payments made to non-residents, since such requirements are only intended to ensure similar levels of compliance between payments to residents and payments to non-residents.”
- 76.
Ibid.
- 77.
The language in Article XIV(e) is ambiguous about whether all matters that are included in an agreement for the avoidance of double taxation are exempted from the most favoured nation obligation under the GATS. For example while it is obvious that differences in withholding tax rates would fall within the exception, do differences in the imposition of indirect taxes fall within the exception if indirect taxes are included in a tax treaty? It would appear the answer to that question is yes based on the wording of the provision.
- 78.
This assumes that resident and non-resident service providers are “like service providers” for purposes of the GATS. See Cossy (2006).
- 79.
The GATS, Article XIV(d). But for this carve-out, the national treatment obligation under the GATS otherwise requires that in the sectors listed in a Member’s schedule of commitments “like” service providers of other Members are to be treated no less favourably than domestic ones. This treatment could be formally identical or formally different, but it would be considered less favourable if it modified the conditions of competition in favour of services or service suppliers of the Member compared to like services or service suppliers of any other Member. This standard was one that many Member States hoped would apply to direct tax measures under the GATS.
- 80.
Tax treaties have primacy over the GATS national treatment obligation in resolving disputes involving the taxation of services and service suppliers.
- 81.
See OECD and UN Model Tax Treaties, Article 24(6).
- 82.
The GATS, Article XIV(e).
- 83.
This issue is discussed further in Chap. 7 at Sect. 7.2.
- 84.
“In the context of the negotiation of the GATS, the European Energy Charter and of a draft multilateral investment on agreement, the Committee on Fiscal Affairs has done considerable work on the issue of the application of such agreements to taxation. This work has revealed that whilst there are good reasons for preventing, or at least limiting, the application of such agreements to tax measures, there is a concern that taxation may be used as a form of disguised discrimination and that the non-discrimination article of tax treaties, in its present form, is not considered by trade or investment experts as an appropriate way to address this concern.” From OECD (2005).
- 85.
At present, there are also few limitations on a country’s tax practices. Customary international law provides virtually no protection against tax discrimination and constitutional or national limitations on tax discrimination against non-residents are rare. The primary restraint against egregious tax practices is international goodwill or limitations imposed in integrated agreements.
- 86.
See for example the Australian treaties with Canada, Malaysia, Mexico, Singapore and the discussion in Chap. 4 at Sect. 4.3.10.
- 87.
See the Canada-Tax Treaty Article XXIX at para 6. This clarification of the role of the tax treaty was considered necessary, notwithstanding that the Protocol was grandfathered under the GATS provisions, as the Third Protocol also extends the non-discrimination article of the Treaty to “all taxes imposed by either contracting state.” Apparently, the negotiators wanted to ensure that these new taxes (including the GST) would be subject to the Tax Treaty dispute resolution mechanism. The amendment to Article XXIX of the Canada-US Tax Treaty to limit the role of the WTO was of no surprise given the very strong position taken by the US during the Uruguay Round.
- 88.
Ibid.
- 89.
The GATS, Article XXII(3) specifically provides that there will be no access to GATS procedures to settle a national treatment dispute concerning a measure that falls within the scope of a tax agreement. In the event of a disagreement between Members as to whether a measure falls within the scope of a tax agreement that existed at the time of the entry into force of the Agreement establishing the World Trade Organization, Article XXII(2), footnote 11, of GATS reserves the resolution of the dispute to the Contracting States under the tax agreement. In such a case, the issue of the scope of a tax agreement may be resolved under GATS procedures (rather than tax treaty procedures) only if both parties to the existing tax agreement consent.
- 90.
The precise scope of the non-discrimination obligations that may apply to non-residents under the GATS and with what effect at best remains unclear. See Farrell (2013).
- 91.
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Brown, C.A. (2017). The General Agreement on Trade in Services. In: Non-discrimination and Trade in Services. Springer, Singapore. https://doi.org/10.1007/978-981-10-4406-9_2
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