United Nation releases 2017
update of the Model Double Taxation Convention between Developed and Developing
Countries; The UN Model Convention introduces new article 12A on 'fees
for technical services' (the article which is absent in OECD's convention); The
2017 update also incorporates some of the language of the BEPS project;
The 2017 UN Model Convention introduces a new general anti-abuse
rule in article 29(9); A note released by the UN Committee states that
"[the new rule] together with the specific anti-abuse rules included in
tax treaties, is intended to prevent transactions and arrangements from being
granted treaty benefits in circumstances where granting such benefits would be
contrary to the object and purpose of the Model Convention"; Article
4 is modified to include a new tie-breaker rule for determining the treaty
residence of dual-resident persons other than individuals and Article 5
is modified to prevent the avoidance of permanent establishment status; The
2017 Model was released during the 16th session of The Committee of Experts on
International Cooperation in Tax Matters of United Nations held this week at
New York
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