With the completion of the 22nd Session of the Committee of Experts on International Co- operation in Tax Matters (U.N. Tax Committee, or UNTC) in April, the term of the current U.N. Tax Committee also comes to an end. During this term (i.e., 2017 to 2021), in addition to changes to the U.N. commentary and other aspects, the UNTC has managed to achieve the following key changes to the United Nations Model Double Taxation Convention between Developed and Developing Countries (U.N. model):
article 121: amendment to the definition of “royalties”;
article 12B: insertion of new article in the U.N. model for taxation of automated digital services; and
article 13: amendment for taxing rights on indirect transfer.
These changes will be incorporated in the 2021 U.N. model and the U.N. commentary. The previous tax committee also achieved the following key changes in the U.N. model:
article 12A: insertion of new article in the U.N. model for taxation of fees for technical services; and
BEPS-related: amendment to the U.N. model related to BEPS project.
These changes were included in the 2017 U.N. model. BEPS-related amendments to the U.N. model were predominantly adaptation in the U.N. model of BEPS-related changes adopted in the OECD model.
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