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This policy paper is the first publication on tax treaties that ATAF has produced for its membership. It seeks to help African governments avoid the pitfalls of tax treaty negotiation and renegotiation and to equip them with tools against tax treaty abuse. A tax treaty is a bilateral agreement between two countries to resolve issues of double taxation and which country should tax investors’ earnings. The two contracting parties are the source and residence countries. The source country, or capital-importing country, hosts the inward investment. The residence country is the capital-exporting country.