UN: Resolution on Negotiating Committee for Framework Convention for International Tax Cooperation
On 14 October 2024 a Resolution was drafted by Nigeria on behalf of the Africa group at the UN, to adopt the terms of reference for the UN Framework Convention on International Tax Cooperation. The draft Resolution referred to the work of the Ad Hoc
See MoreUN Resolution Paves Way for Equitable Global Tax Framework
The UN's Resolution A/C.2/78/L.18/Rev.1, proposed by Nigeria, represents a critical stride in establishing a UN Framework Convention on International Tax Cooperation. It confronts longstanding disparities born from decades of OECD-dominated tax
See MoreGloBE rules to be enforced from January 2024 despite major challenges
The OECD framework Two-Pillar Solution the global corporate minimum tax rate of 15% (Model GloBE Rules), imposed on large multinational companies with annual revenues of $790 million (€750 million) a proposal drafted by the OECD alongside G-20,
See MoreUN: Launch of the updated Model Tax Convention
On 26 April 2022 the launch of the 2021 update of the UN Model Tax Convention took place as part of the UN’s “Financing for Development” forum. There were presentations and a panel discussion. New Articles 12A and 12B The new Article
See MoreUN: Meetings of the Tax Committee
The 24th session of the UN Committee of Experts on International Cooperation in Taxation was held in virtual meetings from 4 to 7 April and 11 to 12 April 2022. Workplans were presented by the various Subcommittees for approval by the
See MoreUN: Tax Committee Discusses Transfer Pricing Issues
In its virtual meetings from 19 to 27 October 2021 the UN Tax Committee is considering aspects of transfer pricing. Among topics that could be pursued further are practical risk assessment tools, transfer pricing aspects of marketing or trading
See MoreUN: Committee of Tax Experts Discuss Model Treaty Provisions
The virtual meetings of the UN Committee of Experts on Tax Matters taking place from 19 to 28 October 2021 are considering issues arising from the UN Model Tax Convention that should be the subject of future discussion within the UN
See MoreUN amends commentary to model tax treaty on taxation of software payments
At the 22nd session of the UN Committee of Experts on International Cooperation in Tax Matters, held virtually between 19 and 28 April 2021, a decision was made to revise the commentary to Article 12 (royalties) of the UN Model Tax Treaty in
See MoreUN: Third edition of the Practical Manual on Transfer Pricing for Developing Countries
Following approval at the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters, held from 19 to 28 April 2021, the UN has published the third edition of its Practical Manual on Transfer Pricing for
See MoreUN: Meeting of Committee of Tax Experts
On 19 to 28 April 2021 the twenty-second session of the UN Committee of Experts on International Cooperation in Tax Matters will be held in a series of virtual meetings. UN Model Treaty – Revised Royalty definition The Committee will
See MoreIMF and World Bank: Discussion of Digital Services Tax
On 13 April 2021 the IMF and World Bank tax conference on Minimum and Digital Taxation: Consensus or Divide discussed aspects of unilateral digital service taxes. The discussions covered the scope of the taxes, tax treaty issues and challenges for
See MorePlatform for Collaboration on Tax: Toolkit on Tax Treaty Negotiations
The Platform for Collaboration on Tax (PCT) was set up by the IMF, OECD, UN and World Bank Group. The PCT has been developing a series of toolkits to guide developing countries in the implementing policy options. The PCT's Toolkit on Tax Treaty
See MoreUN: Proposed Treaty Article on Income from Automated Digital Services
Report by James R. Border, Law Office of James R. Border, P.A., Fort Lauderdale, Florida Over the past several days the UN Committee of Experts on International Cooperation in Tax Matters discussed the work done by Members concerning the tax
See MoreUN: Tax Committee discusses UN Model Commentary Issues – PE, treatment of software, CIVs
A report by James R. Border, Law Office of James R Border P.A., Fort Lauderdale, Florida On 22 October 2020 the United Nations Committee of Experts on International Tax Matters addressed several items relating to the UN Model Tax Convention.
See MoreUN: Committee of Tax Experts to Hold 21st Meeting
The 21st Session of the United Nations Committee of Experts on International Cooperation on Tax Matters will take place from 20 October 2020 to 6 November 2020. The session will be held in scaled-down format using a virtual platform, with virtual
See MoreUN: Subcommittee considers article on taxation of automated digital services
The subcommittee on tax challenges of the digital economy of the UN Committee of Experts on International Cooperation in Tax Matters held a meeting from 25 to 27 August 2020. The subcommittee considered the proposed new Article 12B to the UN
See MoreUN: Draft Model Treaty Provision on Digital Services
On 6 August 2020 the United Nations (UN) published draft Article 12B for the UN Model Double Taxation Convention, to provide for the allocation of taxable income from automated digital services. The draft Article states that income from
See MoreUN: Virtual Meetings of the Committee of Tax Experts
The UN Committee of Experts on International Cooperation in Tax Matters held their twentieth session in the form of a series of virtual meetings from 22 to 26 June 2020. In the meetings the Committee emphasised the need to provide guidance and
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