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
Subscribe to:
Post Comments (Atom)
No Permanent Establishment Unless Proven by the Revenue
The Income Tax Appellate Tribunal (Delhi Bench) recently in the case of SAIC clarified an important principle in international taxation: th...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
The Central Board of Direct Taxes (CBDT) released the Draft Income Tax Rules, 2026 on February 7, 2026. It has invited suggestions and opi...
-
These instructions are guidelines for filling the particulars in this Return Form. In case of any doubt, please refer to relevant provisi...
-
The posting had been move to another website. Please click the link below to get the access of the same. https://taxofindia.wordpress....
-
This Tax Alert summarizes a recent ruling of Customs, Excise and Service Tax Appellate Tribunal, Ahmedabad (CESTAT) [1] . The issue invo...
-
On payment of Contractor, Publisher, Ad-Service Provider etc. above Rs. 20000/- in the financial year, then the TDS is must be deducted u...
-
Anna Covaco is trying to sell her ancestral property - a piece of land worth nearly Rs 10 crores in today's market. Being a senior cit...
-
PENSION SCHEME IN CASE OF AN E MPLOYEE JOINING CENTRAL GOVERNMENT OR ANY OTHER EMPLOYER ON OR AFTER JANUARY 1,2004 New pension s che...
-
An eminent concern within the GST framework pertains to the entitlement of Input Tax Credit (ITC) concerning expenditures associated with In...
-
Section 68 -Cash credits Section 69 -Unexplained investments Section 69A - Unexplained money, etc Section 69B -Amount of investme...
No comments:
Post a Comment