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The UN Model Tax Convention: Recent Developments

The UN Model Tax Convention: Recent Developments

Author: Georg Kofler et al.
Publisher: Kluwer Law International
ISBN: 9789403525792
Published In: December 2025
Format: Hardback
Jurisdiction: ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

The UN Model Tax Convention: Recent developments is a book providing an in-depth analysis of the United Nations Model Double Taxation Convention, a key instrument in international tax law. Designed as a counterpart to the OECD Model, the UN Model responds to the specific concerns of developing countries, aiming to ensure a more equitable allocation of taxing rights between source and residence jurisdictions.

This book examines how the UN Model continues to evolve in response to the changing global tax environment. It explores recent amendments and emerging trends that reflect broader economic transformations, including the rise of the digital economy, the globalization of trade and investment, and increasing calls for tax fairness. Special attention is given to the Model’s emphasis on source-based taxation that is critical in supporting the fiscal sovereignty of developing nations.

What’s in this book:

With contributions from leading academics and practitioners offering both theoretical and practical perspectives, this edited volume provides clear and accessible guidance on such taxation issues and topics as the following:

treatment of income arising from extractives and other natural resources
taxation of income from international shipping and international air transport
taxation of income from cross-border insurance activities
the future of taxing income from cross-border services
taxation of capital gains on shareholdings
cross-border taxation issues involving remote workers
Fast-Track Instrument, and general ‘subject-to-tax’ rule

The chapters are revised and expanded versions of the contributors’ works presented at the 32nd Viennese Symposium on International Tax Law held on 6 June 2025 at WU Vienna University of Economics and Business. Each chapter offers an in-depth analysis of a particular topic referencing the most recent scientific research.

How this will help you:

Through critical analyses and comparative perspectives, this book offers insights into the UN Model’s role in shaping a more balanced and inclusive international tax order. It addresses both the technical and policy dimensions of recent changes, making it an essential resource for tax policymakers, legal practitioners, academics, and international organizations engaged in treaty making and global tax governance.

Preface

CHAPTER 1. Highlights of the Achievements of the UN Tax Committee: And What Was Not Achieved

Liselott Kana

CHAPTER 2.Treatment of Income Arising from Extractives and Other Natural Resources under the UN Model

Alexander Rust & Benjamin Beer

CHAPTER 3. Taxation of Income from International Shipping and International Air Transport under the Revised UN Model Tax Convention

Claus Staringer & Stefan Pregesbauer

CHAPTER 4.Taxation of Income from Cross-Border Insurance Activities under the UN Model: The New Article 12C UN MC

Daniel W. Blum & Timoleon Angelos Christodoulopoulos

CHAPTER 5. Taxation of Fees for Technical Services under the UN Model (Article 12A)

Karoline Spies, Lea Glöer & Matthias Zaman

CHAPTER 6. Taxation of Income from Automated Digital Services under the UN Model (Article 12B)

Georg Kofler & João Ochôa

CHAPTER 7. The Future of Taxing Income from Cross-Border Services under the United Nations Model Convention: Steering Objective Tax Nexus Away from Physical Presence

Pasquale Pistone & Prisca Eleanor Musibi

CHAPTER 8. Cross-Border Taxation Issues Involving Remote Workers under the UN Model: The Proposed Article 15(4) of the UN Model

Gustavo Weiss de Resende

CHAPTER 9. Taxation of Software Payments: Revisiting the Definition of Royalties under the UN Model Convention

Rita Szudoczky & Rafaella Pereira Pedone de Oliveira

CHAPTER 10. Taxation of Capital Gains of Shareholdings under the UN Model

Kristof Boel

CHAPTER 11. Fast Track Instrument to Provide for the Streamlined Amendment of Bilateral Double Taxation Treaties

Lukas Schuster

CHAPTER 12. General ‘Subject-to-Tax’ Rule under the UN Model

Rita Szudoczky & Rhodah Nyamongo