Models with impact, or merely conventional examples? A quantitative exploration of the relationship between the UN Model Convention and the bilateral treaty network on the issue of the taxation of services

Resource Information

The work Models with impact, or merely conventional examples? A quantitative exploration of the relationship between the UN Model Convention and the bilateral treaty network on the issue of the taxation of services represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Models with impact, or merely conventional examples? A quantitative exploration of the relationship between the UN Model Convention and the bilateral treaty network on the issue of the taxation of services

Creator

• Lemmens, M.A

Subject

• UN Model
• model tax treaty
• royalties
• service PE
• PE
• services PE
• tax treaty
• withholding tax
• service fee

Language

eng

Summary

States need revenue to provide for the common basic needs in order for a society to prosper. Taxation is the key source of revenue. As of this importance, taxation remains a policy field in which state sovereignty persists. However, the globalizing world puts pressure on the sovereignty. The international taxation regime, consisting of bilateral treaties, domestic law and model conventions, is evolved to face its challenges. The relationships within this international taxation regime is the topic of this research, more specifically the relationship between model conventions and the bilateral treaty network. A quantitative analysis using the IBFD Tax Treaty Database provides insight in some key trends in the bilateral treaty network with regard to three articles on the taxation of services: the deemed service permanent establishment, the broadened royalty article, and the separate service fee withholding tax article. The result is that there does not seem to be a significant relationship between the UN Model Convention and the bilateral treaties on this highly political topic. Therefore, it seems that one should think twice about promoting model conventions in order to solve problems or faults in this regime that surpass technical and administrative issues

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction