The United Nations has held a launch event for the 2021 version of its model tax convention. The UN model is intended to be used for treaties between developed and developing countries and includes, for example, the concept of a ‘service’ permanent establishment, which does not appear in the OECD model tax convention.
The 2021 update addresses concerns expressed by developing countries regarding the taxation of foreign enterprises on income from automated digital services, and includes new guidance on the application and interpretation of the definition of permanent establishment, the concept of beneficial owner, and the application of the model’s provisions to collective investment vehicles, pensions funds and real estate investment trusts.
The United Nations has held a launch event for the 2021 version of its model tax convention. The UN model is intended to be used for treaties between developed and developing countries and includes, for example, the concept of a ‘service’ permanent establishment, which does not appear in the OECD model tax convention.
The 2021 update addresses concerns expressed by developing countries regarding the taxation of foreign enterprises on income from automated digital services, and includes new guidance on the application and interpretation of the definition of permanent establishment, the concept of beneficial owner, and the application of the model’s provisions to collective investment vehicles, pensions funds and real estate investment trusts.
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