United Nations

Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…

Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…

The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted a…

So what were the other discussions at the UN from 19 to 23 October this year?  One of the main topics is the continuing work on a withholding tax on technical services.  The reason for developing…

It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters.  This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…

The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…

Part 1 of the Report to G20 Development Working group (DWG) on the impact of BEPS in Low Income countries (LICs), dated July 2014, listed in its Section 6: Other High priority BEPS Issues for…

Co-authored with Hans van den Hurk, Maastricht University, QuanteraGlobal Tax Policy. Note that the authors write in their personal capacity. Policymakers are changing the international tax system to…

Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…