Fourteenth Session of the Committee of Experts on International Cooperation in Tax Matters
Substantive matters
- Note by the Secretariat on “Summary of expected modifications to the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 1, 5 and 8, and one general change” ()
- Note by the Secretariat on “Summary of expected modifications to the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 9, 12 and 13” ()
- Note by the Secretariat on “Summary of expected modifications to the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries and commentaries for the 2017 update: articles 23 and 26 and various changes related to consequential base erosion and profit shifting” ()
Background
- Presentation by OECD representative on OECD Model changes relating to international traffic and possible similar changes to the UN Model (E/C.18/2016/CRP.17) – Agenda item 3 (a) (i)
Issues related to the updating of the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries
- Revised Commentary on Article 12A: Fees for Technical services (E/C.18/2017/CRP.1)
- Proposed Addition to the Commentary on Article 12: Fees for Included Services (E/C.18/2017/CRP.2)
- Annex II: Changes to the UN Model Deriving from the Report on BEPS Action Plan 14 (E/C.18/2017/CRP.4.Annex 2)
- Amendments to the Articles of the 51³Ô¹Ï Model Convention Consequential on the Addition of Article 12A (Fees for Technical Services) (E/C.18/2017/CRP.3)
- Coordinator’s Report on Work of the Subcommittee on the Mutual Agreement Procedure—Dispute Avoidance and Resolution (E/C.18/2017/CRP.4)
- Non-Binding Dispute Resolution Potential Changes to Article 25 of the UN Model (E/C.18/2017/CRP.4.Annex3)
- Possible amendments to the commentary on Article 12 (Royalties) in relation to: (i) commercial, industrial and scientific equipment; or (ii) software related payments (E/C.18/2017/CRP.5)
- Carbon taxation – an instrument for developing countries to raise revenues and support national climate policies (E/C.18/2017/CRP.6)
- Proposed Base Erosion and Profit-Shifting Related Changes to the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2017/CRP.7)
- New Article 29 (Entitlement to Benefits) of the UN Model and its commentary (E/C.18/2017/CRP.8)
- Transfer Pricing Issues in Extractive Industries (E/C.18/2017/CRP.9)
- Changes to the UN Model Double Taxation Convention Dealing with the Operation of Ships and Aircraft in International Traffic (E/C.18/2017/CRP.10)
- Secretariat note (E/C.18/2017/CRP.11)
- BEPS: Proposed General Anti-avoidance Rule Commentary for a New Article (E/C.18/2017/CRP.12)
- Proposed Modifications to Article 12 (6) (E/C.18/2017/CRP.13)
- Proposed New Article 1 Commentary (E/C.18/2017/CRP.14)
- Changes to the UN Model Double Taxation Convention Dealing with the Operation of Ships and Aircraft in International Traffic (E/C.18/2017/CRP.15)
- Proposed changes in Article 13 (4) and (5) of the 51³Ô¹Ï Model Double Taxation Convention between Developed and Developing Countries to prevent the granting of treaty benefits in inappropriate circumstances (E/C.18/2017/CRP.18)