By Doug Connolly, MNE Tax
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 a treaty taxing right for source jurisdictions on payments for automated digital services.
The committee voted to include such an article in the UN Model Tax Convention at its session in October 2020. Following the vote, the Subcommittee on Tax Issues related to the Digitalization of the Economy began working on drafting the article and its commentary at sessions held in December 2020 and February 2021.
The subcommittee has now settled several key issues and is working to finalize the language, which it expects to do soon.
Once finalized, the subcommittee expects to present the proposed language for decision at the Tax Committee’s next session, scheduled for April 19–28, 2021.
The committee plans to make the proposed language available on its website before the April session.
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