United Nations

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…

Umberto Lorenzi (Associate Chiomenti)

Italian business calls for tax simplification measures

November 29, 2024

On 22 November 2024 more than 300 tax experts gathered in Rome for the first Italian International tax conference organized by Italian Association of Joint Stock Companies (Assonime). Under the…

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…

Natalia Quinones (Quiñones Cruz Abogados)

The UN Framework Convention On Tax Matters And A New Hope For Multilateralism And Simplification In The Area Of International Taxation

April 3, 2024

Resolution 78/230 was approved by the United Nations General Assembly in December, 2023, creating a mandate for an ad-hoc committee inclusive of all UN member states to draft the terms of reference…

Vikram Chand (Tax Policy Center of the University of Lausanne, Switzerland) , Kinga Romanovska (Tax Policy Center of the University of Lausanne, Switzerland)

The UN Proposal on Revision of Article 8 – Focus Airlines: Critical analysis and our take on whether it is in the Interest of Developing Countries?

February 29, 2024

What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention…

Raffaele Russo (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)

It is time to set up a new international organization on tax matters?

December 21, 2023

Does the helm of command over international tax policy shift to the United Nations? This is the scenario that could be envisioned following the Nov. 22 U.N. General Assembly that approved the…

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

VAT Fixed establishment = permanent establishment? or, should direct and indirect tax practitioners talk to each other?

June 6, 2022

The very recent CJEU judgement in Berlin Chemie A. Menarini v Administraţia Fiscală pentru Contribuabili Mijlocii Bucureşti (Case C-333/20) ECLI:EU:C:2022:291, admirably examined by Giorgio Beretta…