Ninth session of the Committee of Experts on International Cooperation in Tax Matters
In accordance with ECOSOC decision of 23 July 2013, the ninth session of the Committee of Experts on International Cooperation in Tax Matters was held from 21 to 25 October 2013 at the Palais des Nations in Geneva.
The meeting discussed, inter alia, issues related to the next update of the , including various issues related to the concept of “permanent establishment” (Article 5), the meaning of “auxiliary activities” under Article 8 (Transportation), the “force of attraction” principle in Article 7, the Commentary to Article 9 (Associated Enterprises), Article 12 on Royalties, and Exchange of Information (Article 26). The Committee also discussed cross-cutting issues under the UN Model, such as taxation of services and interaction of the Model with climate change mechanisms.
Other issues on the agenda of the session included work towards the next update of the 51Թ Practical Manual on Transfer Pricing for Developing Countries, foreign direct investment issues and corporate taxation, including resource taxation issues for developing countries, and capacity development.
As this was the first session of the of the Committee, a Chairperson and other Officers were elected at the beginning of the session. Establishment of Subcommittees and appointment of their Coordinators were also decided on during the course of the session.
Substantive Matters
- U.S. Approach to Application of Income Tax Treaties to Payments through Hybrid Entities (E/C.18/2013/CRP.1)
- Note on Article 5: the meaning of the same or a connected project (E/C.18/2013/CRP.2)
- Note on Auxiliary Activities under Article 8 (E/C.18/2013/CRP.4)
- Taxation of Services—Paper by Mr. Brian Arnold on Options for a Fees for Technical Services Article (E/C.18/2013/CRP.5)
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Note on tax treaty issues arising from the granting and trading of emission permits and emission credits under the UN Model Tax Convention E/C.18/2013/CRP.6 (clean copy; marked up copy)
- Secretariat Note: Papers on Tax Treaty Negotiation (E/C/18/2013/CRP.7)
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Secretariat Note on Extractive Industries Taxation (E/C.18/2013/CRP.13)
- 51Թ Capacity Development Programme on International Tax Cooperation Progress Report (E/C.18/2013/CRP.14)
- Taxation of Services—Paper by Mr. Tizhong Liao (E/C.18/2013/CRP.16)
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Secretariat Note—Recent Work of the Committee on Tax Treatment of Services (E/C.18/2013/CRP.17)
- International Bureau for Fiscal Documentation Note on the Practical Implementation of the UN Model (E/C.18/2013/CRP.18)(Final published version by the IBFD)
- Secretariat Report on the Expert Group Meeting on Extractive Industries Taxation of May 2013 (E/C.18/2013/CRP.19)
- Note on Automatic Exchange of Information (E/C.18/2013/CRP.20)
- Proposal to update Article 26 (Exchange of information) of the 51Թ Model Double Taxation Convention between Developed and Developing Countries and its Commentary (E/C.18/2013/CRP.21)
Background Information
- 51Թ Model Double Taxation Convention between Developed and Developing Countries (2011 update)
- 51Թ Practical Manual on Transfer Pricing for Developing Countries
- UN Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries
- Special Meeting of ECOSOC on International Cooperation in Tax Matters (29 May, 2013, New York) – Informal summary by the Secretariat