It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters.  This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible for the UN Model Double Taxation Convention and the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing…

The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in 1997, to replace the one terminated during the apartheid era, has provided an opportunity to consider thorny questions of services and permanent establishments. The…

Part 1 of the Report to G20 Development Working group (DWG) on the impact of BEPS in Low Income countries (LICs), dated July 2014, listed in its Section 6: Other High priority BEPS Issues for developing countries, paragraph c), the topic of base erosion through wasteful tax incentives designed to attract investment, labeling it as…

Co-authored with Hans van den Hurk, Maastricht University, QuanteraGlobal Tax Policy. Note that the authors write in their personal capacity. Policymakers are changing the international tax system to counter tax avoidance by multinationals. Has the potential impact on new investment in jobs, growth and development been assessed? An opinion based on UNCTAD’s World Investment Report…

Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is, the state of residence has the primary right to tax with source state entitlement restricted to taxing the profits of permanent establishments. Source…

There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their international operations allow for substantial tax management to minimize the corporate tax burden at group level. A number of tax policy projects are in process and…

When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19. What about employees of international organisations? Although international civil servants, they work for no government and are outside Art 19. Commonly, treaties…