Following a series of consultative meetings led by the UN Tax Committee, a revised version of the Model Double Tax Convention has been released. Among the notable additions are the adoption of Article 12B that deals with income from automated digital services and the guiding commentary on the Article. Coming in on the backdrop of the ongoing debate on taxation of digital services, the model serves as a good reference to help bilateral treaty negotiation. Further amendments have been made to Article 13 (capital gains) of the model to address among others, the issue of offshore indirect transfers.
An official launch of the publication will take place later this month. The details of which can be found here.
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