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The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Romanian tax treaties
On 1 January 2011 Romania was a party to eighty-three tax treaties signed since
This total of eighty-three treaties is made up of the following:
- twenty treaties concluded before 1989, out of which: 1. ten were
concluded with developing countries; and 2. ten were concluded with
developed countries or important business partners of Romania (Cyprus,
Denmark, France, Italy, Japan, Norway, Spain, Sweden, the UK and the
- ten concluded for the first time before 1989 and renegotiated after
1989 as follows: 1. developed countries – Austria, Belgium, Canada,
Finland, Germany and the Netherlands; 2. developing countries –
Morocco, Pakistan, Syria and Yugoslavia;
- fifty-three concluded after 1989, out of which: 1. eighteen were
concluded with states that came into being after 1989 from the former USSR
and Yugoslavia; 2. nine were concluded with former socialist countries; 3.
fourteen were concluded with developing countries; and 4. twelve were
concluded with developed/European countries.
As can be seen, of the thirty treaties concluded before 1989, only twenty
remained in force; of these twenty, ten were concluded with developing countries
representing important commercial partners of Romania in the period before 1989
(Bangladesh, Egypt, India, Jordan, Malaysia, Sri Lanka, Tunisia, Turkey,
Yugoslavia (Bosnia and Herzegovina) and Zambia), the only one country in this
group having an increasing importance for Romania from a commercial perspective
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