United Nations Model Double Taxation Convention Between Developed And Developing Countries 2021
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United Nations Model Double Taxation Convention Between Developed And Developing Countries 2021
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Author : UNITED NATIONS.
language : en
Publisher:
Release Date : 2022
United Nations Model Double Taxation Convention Between Developed And Developing Countries 2021 written by UNITED NATIONS. and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022 with categories.
The United Nations Model Double Taxation Convention between Developed and Developing Countries: 2021 Update is a publication geared towards the international community especially developing countries and countries with economies in transition. Double tax treaties aim to prevent unrelieved double taxation, in order to foster cross-border economic activity and the transfer of technology. The UN Model Tax Convention consists of articles on the treaty's scope and on definitions to be used in the treaty. For different kinds of income and capital, it allocates taxing rights before establishing how double taxation will be eliminated where the taxing rights are shared. It also includes articles that prevent certain forms of tax discrimination; provide for the exchange of tax information and assistance in tax collection between the treaty partners; allow the treaty partners to consult together, through the Mutual Agreement Procedure, to resolve disputes or address doubts concerning the treaty; and address certain types of treaty abuse. The most important changes included in the 2021 version of the UN Model address concerns expressed by developing countries regarding tax treaty obstacles to the taxation of foreign enterprises on income from automated digital services and on gains on so-called “offshore indirect transfers”. The 2021 UN Model also features new guidance on the application and interpretation of the definition of a permanent establishment, the concept of a beneficial owner, and the application of the Model's provisions to collective investment vehicles, pensions funds, and real estate investment trusts. This fifth edition of the UN Model Tax Convention culminates four years of work by the UN Tax Committee and its Subcommittees, supported by the Secretariat in the UN Department of Economic and Social Affairs. Since its first publication in 1980, the Model has been updated previously in 2001, 2011, and 2017.
United Nations Model Double Taxation Convention Between Developed And Developing Countries
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Author : United Nations. Department of Economic and Social Affairs
language : en
Publisher: United Nations Publications
Release Date : 2001
United Nations Model Double Taxation Convention Between Developed And Developing Countries written by United Nations. Department of Economic and Social Affairs and has been published by United Nations Publications this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001 with Double taxation categories.
The growth of investment flows from developed to developing countries depends on the international investment climate. An important component of this climate is the prevention of double taxation, i.e. the imposition of similar taxes in two or more states on the same taxpayer. Bilateral tax treaties have eased this problem and in 1980 the United Nations published a model double taxation convention between developed and developing countries. This has now been revised to take account of the changes in the globalisation of trade and finance since 1980. Although it is based on the OECD Model Convention, there are differences as it gives more weight to the source principle as opposed to the residence principle.
United Nations Model Double Taxation Convention Between Developed And Developing Countries
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Author : United Nations. Department of International Economic and Social Affairs
language : en
Publisher:
Release Date : 1980
United Nations Model Double Taxation Convention Between Developed And Developing Countries written by United Nations. Department of International Economic and Social Affairs and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1980 with Double taxation categories.
Text of and commentaries on a model convention prepared under the auspices of the United Nations Ad Hoc Group of Experts on Tax Treaties between Developed and Developing Countries. The model consists of articles based on guidelines formulated by the Group at its various meetings and their commentaries expressed at those meetings together with commentaries, where appropriate, drawn from the OECD's 1977 Model Tax Convention.
United Nations Model Double Taxation Convention Between Developed And Developing Countries
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Author :
language : en
Publisher: Economic & Social Affairs
Release Date : 2012
United Nations Model Double Taxation Convention Between Developed And Developing Countries written by and has been published by Economic & Social Affairs this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Business & Economics categories.
Text of, and commentary on, the U.N. Model Double Taxation Convention.
United Nations Manual For The Negotiation Of Bilateral Tax Treaties Between Developed And Developing Countries
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Author : United Nations Department of Economic and Social Affairs
language : en
Publisher: United Nations
Release Date : 2016-06-24
United Nations Manual For The Negotiation Of Bilateral Tax Treaties Between Developed And Developing Countries written by United Nations Department of Economic and Social Affairs and has been published by United Nations this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-06-24 with Political Science categories.
The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries provides a guide to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.
United Nations Model Double Taxation Convention Between Developed And Developing Countries
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Author : United Nations
language : en
Publisher:
Release Date : 2018-11-08
United Nations Model Double Taxation Convention Between Developed And Developing Countries written by United Nations and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-11-08 with Business & Economics categories.
The United Nations Model Double Taxation Convention between Developed and Developing Countries: 2017 Update is a publication geared towards the international community especially developing countries and countries with economies in transition. This new revision of the UN Model updates the widely used 2011 version of the Model. It is important for countries that seek assistance in the negotiation and implementation of modern bilateral double tax treaties reflecting their current circumstances and policy priorities. The Model recognizes that to avoid double taxation of investment, country where the investment takes place and country of the investor often share taxing rights. The Model helps to do it in a way that preserves an appropriate share of taxing rights to developing countries. The Model also promotes cooperation to deal with tax avoidance and evasion.
Papers On Selected Topics In Negotiation Of Tax Treaties For Developing Countries
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Author : United Nations Publications
language : en
Publisher:
Release Date : 2014
Papers On Selected Topics In Negotiation Of Tax Treaties For Developing Countries written by United Nations Publications and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Business & Economics categories.
Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.
United Nations Model Double Taxation Convention Between Developed And Developing Countries Revised Version
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Author : Stephen R. Crow
language : en
Publisher:
Release Date : 1999
United Nations Model Double Taxation Convention Between Developed And Developing Countries Revised Version written by Stephen R. Crow and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999 with categories.
Special Features Of The Un Model Convention
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Author : Anna Binder
language : en
Publisher: Linde Verlag GmbH
Release Date : 2019-10-01
Special Features Of The Un Model Convention written by Anna Binder and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-10-01 with Law categories.
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.
United Nations Manual For The Negotiation Of Bilateral Tax Treaties Between Developed And Developing Countries 2019
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Author : United Nations Publications
language : en
Publisher:
Release Date : 2019-07-26
United Nations Manual For The Negotiation Of Bilateral Tax Treaties Between Developed And Developing Countries 2019 written by United Nations Publications and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-07-26 with Political Science categories.
This manual provides insights to all aspects of tax treaty negotiation, including a brief description of the Articles of the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is intended mainly for negotiators with little or no experience in the negotiation of tax treaties.The Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries seeks to provide practical guidance on all aspects of tax negotiation, including how to prepare for and conduct negotiations. Treaty negotiators in developing countries are encouraged to use this Manual in preparing for tax treaty negotiations in light of their country's policy framework and the intended outcomes they wish to achieve. Although the Manual provides a description of the Articles of the UN Model and, where there are differences, of those of the OECD Model Tax Convention on Income and on Capital, it is not intended to replace the detailed Commentaries on these two models; these constitute the most authoritative sources on issues of interpretation of the UN and OECD models and should be consulted in parallel with the Manual