The Tax Programme of the OECD Korea Policy Centre(KPC), in collaboration with the OECD, the Asian Development Bank (ADB), Australian Taxation Office(ATO) and the United Nations Department of Economic and Social Affairs (UNDESA), organised a workshop on “Practical Workshop on the Negotiation of Tax Treaties” from 27–31 October 2025, Sydney, Australia. The workshop was attended by 28 tax officials in the Asia-Pacific region,8 participants from Australia and New Zealand and 8 speakers from the OECD, ADB, Australian Treasury, Inland Revenue Department of New Zealand and UNDESA. The speakers included Néstor Venegas (OECD), John Stokes(OECD), Sara Shearmur (OECD), Carmel Peters(New Zealand), Ronita Ram (Australia), Patricia Brown (UNDESA), Irving Ojeda (UNDESA). 

The workshop took the form of a simulated negotiation of a bilateral double-tax treaty between two fictional countries, which are ‘Fredonia’ and ‘Utopia’. The simulated negotiation was based on treaty models, the previous tax treaties that each of them has signed with other countries, ‘Lilliput’ and ‘Atlantis’, respectively, and the information on the detailed tax systems of the two countries. Each participant became an active debater, assigned to two teams-one representing ‘Utopia’, the other representing ‘Fredonia’. All teams were assigned an instructor to help their group discussions and each member had an opportunity to lead the discussions. 

To prepare for the discussion, participants were given a description of the basic facts and tax laws of two fictional countries, Utopia and Fredonia, and a preview of the contents of Utopia's model treaty, Fredonia's model treaty, Utopia's latest treaty with Atlantis, and Fredonia's latest treaty with Lilliput. They had time to prepare for the negotiations through discussion, and after, they negotiated in groups.