United Nations–MNE Tax

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Proposal for a United Nations Convention on Tax: need new rules for tax transparency, elimination of the arm’s length principle: Tove Ryding / European Network on Debt and Development / Global Alliance for Tax Justice→

March 14, 2022

Multinational

United Nations tax body is needed to address cross-border tax abuse and reform global tax regulations; OECD deal gave developing countries a voice but didn’t listen: José Antonio Ocampo / Project Syndicate→

November 17, 2021

Africa

‘Tax Inspectors Without Borders’ expands developing country tax and transfer pricing assistance

November 9, 2021

Tax Inspectors Without Borders – a joint initiative of the OECD and United Nations Development Programme – expanded the scope of its assistance to developing country tax administrations, according to the initiative’s 2021 annual report released November 9, amid challenges faced by . . .

Featured News

Platform for Collaboration on Tax shifts priorities in response to global tax deal

October 20, 2021

The Platform for Collaboration on Tax – a joint initiative of the OECD, United Nations, International Monetary Fund, and World Bank Group – is reevaluating its international tax priorities in light of the Inclusive Framework agreement reached . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Africa

Kenya tax bill alters permanent establishment definition, increases transfer pricing reporting requirements

June 2, 2021

Ian Mota, Rödl & Partner, discusses Kenya’s Finance Bill 2021, which includes a new “permanent establishment” definition, country-by-country reporting requirement, and new rules for determining “control” among related entities . . .

Europe

The UN transfer pricing manual’s guidance on IP valuation and royalty rates

May 19, 2021

New York City Economist, Dr. J. Harold McClure, discusses the latest edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released April 27, which includes some useful observations on the nature of intangible assets, yet it has a very sparse discussion of the evaluation of intercompany royalty rates . . .

Europe

The UN transfer pricing manual’s guidance on intercompany interest rates in the extractive sector

May 12, 2021

New York City Economist, Dr. J. Harold McClure, discusses several examples in the United Nations transfer pricing manual’s chapter on the extractives sector that address how to set appropriate intercompany interest rates . . .

Featured News

UN declines to amend model tax treaty on software payment taxation

May 4, 2021

The UN Committee of Experts on International Cooperation in Tax Matters, at its 22nd session, decided against adding a proposal to add computer software payments to the UN model tax treaty’s definition of royalty payments . . .

Digital Economy

UN versus OECD – It’s time for the UN to get going

May 4, 2021

Kuldeep Sharma, ADIT (CIOT, UK), discusses why it’s time for the UN to come out of the shadows of the OECD, make structural changes to its tax committee and strengthen its Secretariat to bring it at par with the OECD . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Digital Economy

UN committee considers updates to model tax treaty, developing nation tax guidance

April 21, 2021

The UN Committee of Experts on International Cooperation in Tax Matters has released documents that reveal that significant changes are proposed for the United Nations Model Double Taxation Convention between Developed and Developing Countries and UN guidance addressing . . .

Americas

UN Committee of Experts approves new digital tax article for model treaty

April 20, 2021

The UN Committee of Experts on International Cooperation in Tax Matters today agreed to the text of a new article and commentary for the UN model tax treaty that would grant . . .

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

April 14, 2021

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

Europe

Ireland reevaluating tax treaty policy

April 13, 2021

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Africa

UN tax committee releases updated model treaty language on automated digital services

April 7, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters today released its final draft of proposed Article 12B and commentary on income from automated digital . . .

Asia-Pacific

Mongolia issues first transfer pricing assessment

March 18, 2021

The Mongolian government has issued its first transfer pricing tax assessment, hitting a mining company with a tax bill of approximately USD 228 million and a denial of USD 1.5 billion in carried forward . . .

Inclusive Framework on BEPS

NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group→

March 18, 2021

Featured News

UN tax committee to issue proposed model treaty language on taxing rights for automated digital services

March 15, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has announced that it is finalizing language on a proposed article for inclusion in the UN Model Tax Convention attributing . . .

Featured News

“Platform for Collaboration on Tax” toolkit offers guidance on negotiating tax treaties

March 11, 2021

On March 10, the “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and World Bank Group – launched the final version of its Toolkit on Tax Treaty Negotiations. . .

Africa

Proposed UN model treaty article on automated digital services is simpler than OECD/G20 Inclusive Framework proposal and preserves taxing rights of developing countries, IMF subcommittee says: International Monetary Fund→

February 19, 2021

Africa

Feedback sought on UN model tax treaty provision clarifying taxation of software payments

February 17, 2021

A subcommittee of the UN Committee of Experts on International Cooperation in Tax Matters has released a discussion draft and . . .

Multinational

UN tax committee publishes practices and working methods agreed to at its October 2020 meeting: United Nations Committee of Experts on International Cooperation in Tax Matters→

February 3, 2021

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

January 19, 2021

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Digital Economy

UN tax committee releases official report on outcome of 21st session: Committee of Experts on International Cooperation in Tax Matters→

December 2, 2020

Digital Economy

UN to add automated digital services article to model tax treaty

November 9, 2020

The UN Committee of Experts on International Cooperation in Tax Matters has agreed to add . . .

Multinational

UN tax subcommittee PowerPoint shows plan for new handbook for policymakers on carbon tax: United Nations→

October 28, 2020

Africa

Transfer pricing in Kenya: beyond Unilever

October 22, 2020

New York economist Dr. J. Harold McClure discusses the new Kenya chapter in the United Nations Practical Manual on Transfer Pricing for Developing Countries and Kenya’s loss in a transfer pricing dispute with Unilever . . .

Africa

UN tax committee to consider adding new automated digital services article to model convention

October 20, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss the UN Committee of Experts on International Cooperation in Tax Matters plans to consider at its 21st session a proposed new model tax convention article that addresses automated digital services income . . .

Africa

UN tax committee to weigh updates to model treaty, transfer pricing manual

October 20, 2020

The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its 21st session today, meeting virtually to discuss transfer pricing . . .

Multinational

NGO expresses support for UN model tax treaty clarification providing that all payments for rights to use computer programs or software are covered in royalties article: The BEPS Monitoring Group→

October 6, 2020

Multinational

Tax Inspectors Without Borders activities described in new report: OECD/UNDP→

September 30, 2020

Asia-Pacific

Tax Inspectors Without Borders, a joint OECD/UNDP initiative, has launched its first program in Kazakhstan: TIWB / Twitter→

September 17, 2020

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

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 . . .

Americas

Economist calls on UN development agency to oppose EU tax blacklisting of Barbados and other small states, calling the action “blatantly discriminatory” policy: Marlon Madden / Barbados Today→

September 1, 2020

Digital Economy

UN subcommittee advances model tax treaty article on automated digital services

August 31, 2020

A UN Committee of Experts on International Cooperation in Tax Matters subcommittee has concluded that the drafting group developing proposed UN model tax treaty Article 12B, addressing the taxation of automated. . .

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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Sept. 4 – 8	IFA Congress	Berlin