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Pris: 2598 SEK exkl. moms  |  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.
Table Of Contents
Editors
Contributors
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 | | |
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