The UN Committee of Experts on International Cooperation in Tax Matters is to meet from 19 to 23 October 2015. Their agenda includes discussion of issues relating to the UN Model Tax Convention; and the next update of the UN Practical Manual on Transfer Pricing for Developing Countries. The experts are also to discuss the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries.

Other topics for discussion include taxation of the extractive industries; taxation of development projects; and capacity building. Also on the agenda is the issue of dispute settlement and ways forward on arbitration issues; and tax issues surrounding international trade in goods.

Treaty issues

The tax treaty issues to be discussed include Article 1 (persons covered) of the UN Model and the issue of the application of tax treaty provisions to hybrid entities. The experts are also to discuss the meaning of “connected projects” in Article 5 (permanent establishment) of the UN Model. Some aspects of the article on shipping and air transport are also on the agenda including the meaning of auxiliary activities and the application of the article to cruise shipping.

A discussion is planned on the implications for the UN Model of measures to combat base erosion and profit shifting. The experts are also to consider Article 12 (royalties) and the meaning of industrial, commercial and scientific equipment as well as issues related to payments for software. Other treaty issues to be discussed include the article on technical services and the article on exchange of information.