UN Tax Convention

Dispute resolution, International Investment Agreements, UN Tax Convention, United Nations

(Head of Tax Policy Center, University of Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA)) and (Prof. Dr. Adolfo Martín Jiménez, University of Cádiz)/ /Leave a comment

Prof. Dr. Robert J. Danon, University of Lausanne /DANON /Prof. Dr. Adolfo Martín Jiménez, University of Cádiz/AMJ ITC On 24-27 March 2025, the United Nations Committee of Experts on International Cooperation in Tax Matters (“UN Tax Committee”), in its 30th session, approved the latest changes to a new clause to be introduced into art. 25…

Arbitration, Arm's Length, BEPS, Double Taxation, International Tax Law, MAPs and APAs, Norway, OECD, OECD MC Convention, Permanent Establishments, Tax Treaties, Transfer Pricing, UN Tax Convention, United Nations

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD gathers and publishes statistical data on such cases separate from all other kinds of tax treaty disputes. Recourse to MAP to…

Arm's Length, Company, Developing Countries, Direct taxation, Double Taxation, Finland, income tax, India, International Tax Law, MNE Profits, MNEs, OECD, OECD MC Convention, Permanent Establishments, South Africa, Tax Treaties, Transfer Pricing, UAE, UN Tax Convention, Uncategorized, United Kingdom, United Nations, United States

(Temple Tax Chambers; King’s College London)/ /1 Comment

“When I use a word,” Humpty Dumpty said in rather a scornful tone, ” it means just what I choose it to mean, neither more nor less.” (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD’s 10 year project on attribution of profits to permanent establishments, there were very few reported cases on…

BEPS, G20, Global minimum tax, GloBE, OECD, Pillar II, QDMTT, UN Tax Convention

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam)/ /Leave a comment

Summary While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF countries accept the Pillar Two Model Rules and guidance and everything that is devised within the IF context as part of the ‘common approach’…

Canada, Direct taxation, Double Taxation, Individuals, International Tax Law, MAPs and APAs, OECD, OECD MC Convention, Personal income tax, Tax Treaties, UN Tax Convention, Unitary Taxation, United States

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet specific requirements of contracting states.  The United States is a case in point. Since it taxes its citizens…

UN Tax Convention, United Nations

, (Full Professor of Financial and Tax Law, Complutense University of Madrid Visiting Professor of Transnational Taxation, Northwestern University)/ /Leave a comment

The terms of reference (ToR) adopted by the Ad Hoc Committee[i] will be submitted to the UN General Assembly and voted during its 79thth session – taking place from 10 to 24 September 2024 in New York. If these terms of reference are adopted, the negotiating committee will be expected to submit a final text…