22nd Session of the Committee of Experts on International Cooperation in Tax Matters
Virtual informal meetings: 19 – 23 April and 26 – 28 April 2021
The final report of the twenty-second session (E/2021/45/Add.2-E/C.18/2021/2) is now available, in Arabic, Chinese, English, French, Spanish and Russian.
The 22nd Session was held virtually, with the meeting component from 19 – 23 April and 26 – 28 April 2021, 8:00 -11:00 am New York Time.
The session was the final session of the current Membership of the Committee, concluding its ambitious work programme for the 2017-2021 period.
The Committee was globally recognized for its work in shaping international tax norms and providing policy and practical guidance to help countries in mobilizing domestic resources for sustainable development. The Committee did this by focusing on broadening country tax bases; avoiding both “double (or multiple) taxation” and “non-taxation” of taxable profits; and identifying and generating fresh guidance on new and emerging issues in international cooperation in tax matters, both domestic and international. It gave special focus in all of its work to the least developed countries and other countries in special situations.
The Committee comprises 25 members nominated by Governments and acting in their expert capacity, drawn from the fields of tax policy and tax administration and reflecting the diversity of the UN membership, in terms of geographical regions and tax systems. Its work benefits from multi-stakeholder engagement in its subcommittees. Its meetings were open to participation by observers from Member States and other stakeholders, including international and regional organizations, academia, civil society and private sector.
AGENDA
Monday, 19 April 2021
Dispute avoidance and resolution
- (E/C.18/2021/CRP.2) Preface and Chapter 1 (Introduction and Overview) of the Handbook on Dispute Avoidance and Resolution
- E/C.18/2021/CRP.16) Changes to paragraph 25 of the Commentary on Article 25 of the United Nations Model Double Taxation Convention between Developed and Developing Countries
Tax consequences of the digitalized economy
- (E/C.18/2021/CRP.1) Tax consequences of the digitalized economy – issues of relevance for developing countries
Submissions received
- World Bank Group Staff Comments on Proposed UN Article 12B of the UN Model Tax Convention (Automated Digital Services)
- IMF Staff Comments on Proposed UN Article 12B of the UN Model Tax Convention (Automated Digital Services)
- US National Foreign Trade Council
- Digital Economy Group (Baker McKenzie)
- (E/C.18/2021/CRP.15) Proposed Changes to the UN Model including the Commentaries thereon as a consequence of the proposed inclusion of Article 12B on automated digital services
- (E/C.18/2021/CRP.15 Rev.1) Proposed Changes to the UN Model including the Commentaries thereon as a consequence of the proposed inclusion of Article 12B on automated digital services
- (E/C.18/2021/CRP.17) Editorial changes to the approved text for Article 12B and its Commentary
- (E/C.18/2021/CRP.17 Rev.1) Editorial changes to the approved text for Article 12B and its Commentary
- (E/C.18/2021/CRP.18) Changes to the Commentary on Article 12 of the United Nations Model Double Taxation Convention between Developed and Developing Countries to reflect decisions made at the 22nd Session with respect to the inclusion of Article 12B and the treatment of computer software
- (E/C.18/2021/CRP.19) Changes to Article 23A and its Commentary to reflect the inclusion of Article 12B in the United Nations Model Double Taxation Convention between Developed and Developing Countries
Tuesday, 20 April 2021
Tax consequences of the digitalized economy (Cont.)
Wednesday, 21 April 2021
Extractive industries – updating of the Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries
- (E/C.18/2021/CRP10) Update of the Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries (Chapter 1)
- (E/C.18/2021/CRP11) Chapter XX: The tax treatment of decommissioning (update)
- (E/C.18/2021/CRP12) Chapter XX: Issues and Best Practices in Auditing Oil, Gas and Mining Activities (new)
- (E/C.18/2021/CRP13) Chapter 5: Transfer Pricing Issues in Extractives (update)
- (E/C.18/2021/CRP.14) Update of the Handbook on Selected Issues for Taxation of the Extractive Industries by Developing Countries
Thursday, 22 April 2021
Extractive industries (Cont.)
UN Model - updating the UN Model Double Taxation Convention between Developed and Developing Countries
Submissions received
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- Annuar Nurakhmet comments on the discussion draft on the inclusion of software payments in the definition of royalties
- BEPS Monitoring Group (BMG) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Bombay Chartered Accountants' Society (BCAS) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Confederation of British Industry (CBI) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Ganesh Rajgopalan comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Information Technology Industry Council (ITI) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- International Chamber of Commerce (ICC) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- International Tax and Investment Center ITIC comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Radhakishan Rawal comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Silicon Valley Tax Directors Group (SVTDG) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- Software Coalition comments on the discussion draft on the inclusion of software payments in the definition of royalties
- South Centre Tax Initiative (SCTI) comments on the discussion draft on the inclusion of software payments in the definition of royalties
- United States Council for International Business (USCIB) comments on the discussion draft on the inclusion of software payments in the definition of royalties
Friday, 23 April 2021
UN Model - updating the UN Model Double Taxation Convention between Developed and Developing Countries (Cont.)
Environmental tax issues
- (E/C.18/2021/CRP3) Coordinator’s report (with the complete, unedited version of the Handbook) – for INFORMATION
- (E/C.18/2021/CRP4) Chapter 1: Introduction – for DISCUSSION and APPROVAL
- (E/C.18/2021/CRP5) Chapter 3 [Former Chapter XX]: How to generate public acceptability for carbon taxes – for DISCUSSION and APPROVAL
- (E/C.18/2021/CRP6) Chapter 4A [Former Chapter 3A], Section 5.5.2: International maritime transport – for DISCUSSION and APPROVAL
- (E/C.18/2021/CRP7) Chapter 6 [Former Chapter 5]: Revenue use – for DISCUSSION and APPROVAL
- (E/C.18/2021/CRP8) Chapter 7 [Former Chapter 6]: Carbon taxation: Interaction with other instruments – for DISCUSSION and APPROVAL
Monday, 26 April 2021
Capacity Building
Dispute avoidance and resolution
Tax consequences of the digitalized economy (Cont if needed)
Tuesday, 27 April 2021
UN Model - updating the UN Model Double Taxation Convention between Developed and Developing Countries (Cont if needed)
Transfer pricing – updating of the UN Practical Manual on Transfer Pricing for Developing Countries
Wednesday, 28 April 2021
Tax and Sustainable Development Goals
Provisional Agenda for 23rd Session
Other matters
STATEMENTS AND OTHER DOCUMENTATION
UN Journal - Click HERE