Submission on Changes to the United Nations Model Double Taxation Convention, October 2020
Comments on Discussion Draft: Possible Changes to the United Nations Model Double Taxation Convention Between Developed and Developing Countries Concerning Inclusion of software payments in the definition of royalties
The South Centre Tax Initiative (SCTI) offers its comments on the discussion draft on inclusion of software payments in the definition of royalties. As is well known, this is an important issue that developing countries have been fighting for, for a while now. The SCTI supports the proposed change which seeks to insert the phrase “computer software” in article 12(3) of the United Nations Model Double Taxation Convention Between Developed and Developing Countries. The COVID-19 pandemic adds special urgency to resolving this long-pending issue as revenue from software payments made from developing countries continues to increase.
Download Submission below:
This article was tagged: Base Erosion and Profit Shifting Project (BEPS), COVID-19, Digital Economy, Digital Taxation, Double Taxation, Intellectual Property Rights (IPRs), International Monetary Fund (IMF), Multinational Enterprises (MNEs), Organisation for Economic Co-operation and Development (OECD), Royalties, Software Payments, South Centre Tax Initiative (SCTI), Tax Cooperation, Tax Law, Tax Policy, Tax Reform, UN Model Double Taxation Convention, Withholding Taxes, World Bank
