UN Tax Convention

Robert Danon (Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA)) , Prof. Dr. Adolfo Martín Jiménez (Prof. Dr. Adolfo Martín Jiménez, University of Cádiz)

The Override of International Investment Agreements by Double Taxation Conventions in the Latest UN Model Tax Convention: Critical comments

April 15, 2025

Prof. Dr. Robert J. Danon, University of Lausanne /DANON /Prof. Dr. Adolfo Martín Jiménez, University of Cádiz/AMJ ITC On 24-27 March 2025, the United Nations Committee of Experts on International…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Transfer Pricing corresponding adjustments as of right

April 8, 2025

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Just how far does the AOA go?

February 5, 2025

"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD…

Maarten de Wilde (Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam)

Two Pillars early ‘25: Ridiculousness

February 3, 2025

Summary While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Credit where credit is due

January 7, 2025

Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet…

Maria Amparo Grau Ruiz , Maria Amparo Grau Ruiz (Full Professor of Financial and Tax Law, Complutense University of Madrid Visiting Professor of Transnational Taxation, Northwestern University)

United Nations Tax Framework Convention: Terms of Reference for an Inclusive and Effective International Tax Cooperation? Critical Issues

September 6, 2024

The terms of reference (ToR) adopted by the Ad Hoc Committee[i] will be submitted to the UN General Assembly and voted during its 79thth session - taking place from 10 to 24 September 2024 in New…