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UN Headquarters, New York
Report on the fourteenth session of the Committee of Experts on International Cooperation in Tax Matters (E/2017/45-E/C.18/2017/3) – 3-6 April 2017
Substantive Matters:
- Report on the fourteenth session of the Committee of Experts on International Cooperation in Tax Matters (E/2017/45-E/C.18/2017/3)
- Report on the twelfth and thirteenth sessions of the Committee of Experts on International Cooperation in Tax Matters (E/2016/45-E/C.18/2016/7)
- Note by the Secretariat on “Summary of expected modifications to the United Nations Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 1, 5 and 8, and one general change” (E/C.18/2017/INF/1)
- Note by the Secretariat on “Summary of expected modifications to the United Nations Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 9, 12 and 13” (E/C.18/2017/INF/2)
- Note by the Secretariat on “Summary of expected modifications to the United Nations Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 23 and 26 and various changes related to consequential base erosion and profit shifting” (E/C.18/2017/INF/3)
Background:
- Presentation by OECD representative on OECD Model changes relating to international traffic and possible similar changes to the UN Model (E/C.18/2016/CRP.17) – Agenda item 3 (a) (i)
- Issues related to the updating of the United Nations Model Double Taxation Convention between Developed and Developing Countries
- Revised Commentary on Article 12A: Fees for Technical services (E/C.18/2017/CRP.1)
- Proposed Addition to the Commentary on Article 12: Fees for Included Services (E/C.18/2017/CRP.2)
- Annex II: Changes to the UN Model Deriving from the Report on BEPS Action Plan 14 (E/C.18/2017/CRP.4.Annex 2)
- Amendments to the Articles of the United Nations Model Convention Consequential on the Addition of Article 12A (Fees for Technical Services) (E/C.18/2017/CRP.3)
- Coordinator’s Report on Work of the Subcommittee on the Mutual Agreement Procedure—Dispute Avoidance and Resolution (E/C.18/2017/CRP.4)
- Non-Binding Dispute Resolution Potential Changes to Article 25 of the UN Model (E/C.18/2017/CRP.4.Annex3)
- Possible amendments to the commentary on Article 12 (Royalties) in relation to: (i) commercial, industrial and scientific equipment; or (ii) software related payments (E/C.18/2017/CRP.5)
- Carbon taxation – an instrument for developing countries to raise revenues and support national climate policies (E/C.18/2017/CRP.6)
- Proposed Base Erosion and Profit-Shifting Related Changes to the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2017/CRP.7)
- New Article 29 (Entitlement to Benefits) of the UN Model and its commentary (E/C.18/2017/CRP.8)
- Transfer Pricing Issues in Extractive Industries (E/C.18/2017/CRP.9)
- Changes to the UN Model Double Taxation Convention Dealing with the Operation of Ships and Aircraft in International Traffic
- Secretariat note (E/C.18/2017/CRP.11)
- BEPS: Proposed General Anti-avoidance Rule Commentary for a New Article (E/C.18/2017/CRP.12)
- Proposed Modifications to Article 12 (6) (E/C.18/2017/CRP.13)
- Proposed New Article 1 Commentary (E/C.18/2017/CRP.14)
- Changes to the UN Model Double Taxation Convention Dealing with the Operation of Ships and Aircraft in International Traffic (E/C.18/2017/CRP.15)
- Proposed changes in Article 13 (4) and (5) of the United Nations Model Double Taxation Convention between Developed and Developing Countries to prevent the granting of treaty benefits in inappropriate circumstances (E/C.18/2017/CRP.18)
Additional: