From October 11 through October 14, 2016 the United Nations organized the Twelfth Session of the Committee of Experts on International Cooperation in Tax Matters. According to the provisional agenda and organization of work as made available by the United Nations in this respect some interesting items were scheduled to be discussed.
According to this provisional agenda a.o. the following subjects were discussed during this Twelfth Session of the Committee of Experts on International Cooperation in Tax Matters:
Point 3 of the agenda is titled: “Discussion of substantive issues related to international cooperation in tax matters”:
(a) Issues related to the updating of the United Nations Model Tax Convention:
(i) Article 1 (Persons covered): application of treaty rules to hybrid entities;
(ii) Article 8 (Shipping, inland waterways transport and air transport): the meaning and coverage of the term “profits from the operation of ships or aircraft in international traffic”;
(iii) Article 12 (Royalties): possible amendments to the commentary on article 12 in relation to:
a. Industrial, commercial or scientific equipment;
b. Software-related payments;
(iv) Article 23 A (Exemption method): minority view on inclusion of paragraph 4;
(v) Article 26 (Exchange of information): proposed Code of Conduct;
(vi) Taxation of services:
a. Commentary on the article on technical services;
b. Proposed article 12 alternative;
(vii)Base erosion and profit-shifting;
(b) Other issues:
(i) Update of the United Nations Practical Manual on Transfer Pricing for Developing Countries;
(ii) Taxation of the extractive industries;
(iii) Taxation of development projects;
(iv) Capacity-building;
(v) Mutual agreement procedure — dispute avoidance and resolution;
(vi) International trade in goods — tax issues;
(vii)Tax incentives — presentation by delegate from the International Monetary Fund.
Click here to be forwarded to the provisional agenda and organization of work as available on the website of the United Nations, which will open in a new window.
With respect to the meeting the United Nations also published some background documents and notes by the Secretariat with respect to the subjects discussed. Links to these background documents and Notes by the Secretariat can be found here on the website of the United Nations. The Notes of the Secretariat can be found under the tab “Substantive matters”, the background documents can be found under the tab “Background”.
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