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.
