After the 16th Session of UN Committee of Experts on International Cooperation in Tax Matters in New York during May 14 to 17, the United Nations updates the 2017 UN Model Double Taxation Convention between Developed and Developing Countries (UN MC).
The United Nations Model Convention gives more weight to the source principle than the residence principle, compared with the OECD Model Convention. The Committee has undertaken work on BEPS issues and commenced the refurbishing process of the UN MC in 2014 by incorporating the outcome of the work to address BEPS issues. Particularly, following the work by the OECD and G20 on Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), the Committee took note of the considerations identified by the OECD and suggests countries to consider them additionally beside the UN MC.
Amendments Compared with the 2012 Edition
The main differences between the Articles of this version and the previous version published in 2012 include:
Commentaries of the amended articles have been changed accordingly.
Source: United Nations
With the fast growth of China’s economy and the continuous improvement of the comprehensive strength of domestic enterprises, as well as the implementation of the “One Belt, One Road” policy, an increasing amount of Chinese enterprises are beginning to expand their global footprint and establish their presence in Europe.
TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):