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Article 12B UN Model Convention 2021: The UN’s Response to the Tax Challenges Arising From the Digitalization of the Economy.

Article 12B UN Model Convention 2021: The UN’s Response to the Tax Challenges Arising From the Digitalization of the Economy.

Author: Christian Knotzer
Publisher: Kluwer Law International
ISBN: 9789403524788
Published In: July 2024
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 1,065.00

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Description
Contents

Details

The author thoroughly scrutinizes the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are.

What’s in this book:

This book furnishes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail. The author’s in-depth analysis covers all aspects of the article and its significance, including the following:

how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims
legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A
influence of developing countries in forums of international tax coordination
the value of country positions and minority views in Model Conventions
categories of digital services
the novel option for annual net taxation in Article 12B(3) UN Model Convention, and
the proposal for a UN fast-track instrument

How this will help you:

The ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. In light of the clear explanation of how Article 12B UN Model Convention works, this book will prove to be invaluable to practitioners and policymakers who face this issue in their day-to-day work and will benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.

Summary

Acknowledgements

PART I: Setting the Scene

CHAPTER 1. Introduction: The Quest for Taxing the Digital Economy

CHAPTER 2. Research Questions and Structure of the Book

CHAPTER 3. Article 12B UN MC and Principles Underlying the Coordination of Taxing Claims

CHAPTER 4. The Influence of Developing Countries in Forums of International Tax Coordination

PART II: Article 12B UN MC as a Response to the Tax Challenges Stemming from the Digitalization of the Economy

CHAPTER 5. The Response of the UN MC: Article 12B UN MC

PART III: The Relation of Article 12B UN MC to OECD/Inclusive Framework Pillar One/Amount A

CHAPTER 6. OECD/IF Pillar One/Amount A: Reallocation of Taxing Rights

PART IV: Conclusions