The UN Proposal on Revision of Article 8 – Focus Airlines: Critical analysis and our take on whether it is in the Interest of Developing Countries?
What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention between Developed and Developing Countries (“UN Model 2021”)[1] offers two alternatives under Article 8. Alternative A aligns with the OECD Model Tax Convention on Income and…