(a) the effectiveness of proposed tax incentives in achieving their stated policy goals; (b) the revenue costs likely to be suffered by the fiscus of each of the State Parties as a result of the application of proposed tax incentives; (c) the extent to which the absence of Tax Sparing Arrangements in Tax Agreements between State Parties reduce the effectiveness of tax incentives, particularly those aimed at attracting foreign direct investments; (d) the impact that proposed tax incentives will have on the collective costs of, or collective burden on, tax administration in the Region; and (e) the effects that tax incentives have on the overall distribution of the tax burden within each State Party. ARTICLE 5 TAX AGREEMENTS 1. State Parties shall, collectively, develop a common policy for the negotiation of Tax Agreements between or amongst themselves or with countries outside the Region. 2. Each State Party shall, in accordance with its constitutional procedures, strive to ensure the speedy negotiation, conclusion, ratification and effective implementation of Tax Agreements. 3. State Parties shall, collectively, take such steps as are necessary to establish amongst themselves a comprehensive network of agreements for the avoidance of double taxation that will assist in expediting the effective exchange of information, mutual agreement procedures and co-operation amongst themselves. 4. State Parties shall, in pursuit of a common policy for dealing with Tax Agreements, develop a Model Tax Agreement for SADC that, among other things, takes account of the particular socio-economic development needs of each State Party. 5. State Parties shall, on completion of the Model Tax Agreement referred to in paragraph 4, draw up guidelines for the effective exchange of information, the implementation of Mutual Agreement procedures. 48

Select target paragraph3