The Resource Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article

Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article

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Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article
Title
Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article
Creator
Subject
Language
eng
Summary
One of the most important changes in the update of the UN Model of 2017, released in May 2018, is the introduction of a new Article 12A dedicated to fees for technical services. This article analyses the policy considerations which underly the new provision and describes past and current tax treaty practice with regard to the allocation of taxing rights on fees for technical services. It examines the scope of the new model Article 12A and its interaction and potential overlap with items of income covered under Article 5 and Article 7 (permanent establishment and business profits), Article 12 (royalties) and Article 14 (independent services) of the UN Model. In the final section, it analyses how the new provision might play a significant role in the taxation of (certain business models of) the digital economy
Citation source
In: British tax review. - London. - (2018), no. 4 ; p. 422-440
http://library.link/vocab/creatorName
  • Falcão, T
  • Michel, B
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • developing countries
  • tax treaty
  • UN Model
  • royalties
  • technical services
  • allocation of taxing rights
  • tax authorities
  • digital economy
Label
Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article
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Publication
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Scope and interpretation of article 12A : assessing the impact of the new fees for technical services article
Publication

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