OECD
UN model treaty proposal would impose withholding tax on software payments
Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .
Public input sought on Brazil, OECD transfer pricing harmonization
Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .
Draft toolkit on the art of tax treaty negotiation offers tips for developing countries
Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .