Fifth session of Committee of Experts on International Cooperation in Tax Matters

Outcome:

Report on the fifth session of the Committee of Experts on International Cooperation in Tax Matters (E/2009/45 (SUPP)-E/C.18/2009/6 (SUPP))

Organizational Matters:

• Provisional agenda and organization of work (E/C.18/2009/1)
• UN Tax Committee Mandates for Subcommittee and Working Groups, and Related Matters (Subcommittee Mandates)

Substantive Matters:

• Note by the Secretariat: Recent work of the Organization for Economic Cooperation and Development on the attribution of profits to permanent establishments: implications for the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2009/2)
• Tax treaty process for developing countries (E/C.18/2009/3)
• Outcomes of recent conferences relevant to the Committee of Experts (E/C.18/2009/4)
• Transfer Pricing Practical Manual for Developing Countries (E/C.18/2009/5)

Conference room papers (CRP)

Please note that for logistical reasons we will most likely be able to supply Committee Members only with the larger conference room paper (CRP) documents in Geneva, including the draft Manual for the Negotiation of Bilateral Tax Treaties and documents over 50 pages long. We urge other participants to bring electronic or paper copies of such documents to the Annual Session.

• Definition of Permanent Establishment (Advance Unedited Version-E/C.18/2009/CRP.1)
• Proposed Code of Conduct (Advance Unedited Version-E/C.18/2009/CRP.2)
• Revision of UN Treaty Negotiation Manual (Advance Unedited Version-E/C.18/2009/CRP.3)
• Article 14 and the Tax Treatment of Services (Advance Unedited Version-E/C.18/2009/CRP.4)
• General Issues in the Review of Commentaries (Advance Unedited Version-E/C.18/2009/CRP.5)