The UN Committee of Experts on International Cooperation in Tax Matters published several documents in tax matters. Two of the documents are discussing possible updates to the UN Model Double Taxation Convention between Developed and Developing Countries commentary on permanent establishments and beneficial ownership.
UN tax committee is proposing updates to the commentary of Article 5 (permanent establishment) to reflect changes that were incorporated into the 2017 OECD Model Commentary. The changes include the following:
The subcommittee paper presenting a high-level discussion of the issue of beneficial ownership was also released. The paper notes that in 2014 beneficial ownership was clarified in the OECD model treaty. The paper considers whether an update should also be provided in the UN treaty within article 10, 11, and 12.
The documents will be discussed during the 18th session of the Committee, which will be held 23 to 26 April 2019.
Source: United Nations
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