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 informal meetings from 20 – 23 October 2020 and 26 – 29 October 2020.
The session will discuss the latest update of the UN Practical Manual on Transfer Pricing for Developing Countries. A new chapter on financial transactions has been drafted and the Committee will discuss changes relating to comparability; updates on group synergies and material on central procurement functions.
Discussions will also focus on updates for the UN Model Tax Convention including possible updates relating to permanent establishments; transparent entities; CIVs, pension funds and REITs; the definition of a beneficial owner; capital gains on offshore indirect transfers; and the application of the Article 13 (royalties) to software payments.
The session will consider updates to the Handbook on Selected Issues for the Taxation of Extractive Industries by Developing Countries, including updates on tax incentives in the oil industry, the tax treatment of subcontractors, production sharing contracts and the tax treatment of financial transactions.
Environmental tax issues will be discussed, including the first sections of a new publication on the design and application of a carbon tax. The session will also discuss a new UN handbook on tax dispute avoidance and resolution. Other agenda items include the tax consequences of the digitalized economy; tax treatment of ODA projects; and capacity support provided by UNDESA.
The Committee provides practical guidance for governments, tax administrators and taxpayers, focussing on the issues facing developing countries.