Source-Based Taxing Rights from the OECD to the UN Model Conventions: Unavailing Efforts and an Argument for Reform
Bibliographic record
Abstract
Abstract A significant number of scholars have written about the nexus between fairness in the allocation of taxing rights in double taxation treaties and sustainable development in developing countries. These scholars have argued for expansive taxing rights for developing countries, as against the current source- restricting provisions in taxation treaties between developed and developing countries based on the OECD and UN Model taxation treaties. They have also highlighted the need for developing countries to critically assess their treaty networks, and to consider gaps in their local laws and policies that encourage revenue loss. This paper contributes to this body of knowledge by identifying provisions in Nigeria’s double taxation treaties that encourage revenue loss. It concludes by recommending amendments to Nigeria’s double taxation treaties.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.021 | 0.038 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.002 | 0.002 |
| Science and technology studies | 0.003 | 0.021 |
| Scholarly communication | 0.009 | 0.009 |
| Open science | 0.002 | 0.005 |
| Research integrity | 0.006 | 0.012 |
| Insufficient payload (model declined to judge) | 0.004 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".