UN: Documents of the 10th Session of the Committee of Experts on International Cooperation in Tax Matters

Par Robert Robillard - 21 novembre 2014

Voir le site EN FRANÇAIS

RBRT Inc. Transfer pricing, tax treaties and other international tax matters

Gratte-ciel

The documents related to the 10th Session of the Committee of Experts on International Cooperation in Tax Matters which was held in Geneva from October 27 to 31, 2014 are now available online.

From the UN website:

« Substantive Matters

  • Note by the Secretariat on « Subcommittee on Extractive Industries Taxation Issues for Developing Countries » (E/C.18/2014/2)
  • Note by the Secretariat on “Differences between article 12 of the UN Model Double Taxation Convention between Developed and Developing Countries and article 12 of the OECD Model Tax Convention on Income and Capital” (E/C.18/2014/3)
  • Note by the Secretariat on « Update of the commentary on article 9 of the United Nations Model Double Taxation Convention between Developed and Developing Countries » (E/C.18/2014/4)
  • Note by the Secretariat on « An introduction to tax treaties » (E/C.18/2014/5)

Additional Documents:

Conference room papers (CRP)

  • Secretariat Note on Auxiliary Activities under Article 8 (E/C.18/2014/CRP.1)
  • Secretariat Note on Application of Article 8 to Cruise Shipping (E/C.18/2014/CRP.2)
  • Report of the Coordinator on Subcommittee on Extractive Industries Taxation Issues for Developing Countries (E/C.18/2014/CRP.3)
    • Attachment A: Draft Outline of Overview Note on Extractive Industries Taxation Issues
    • Attachment B: Capital Gains Taxation and Indirect Sales
    • Attachment C: VAT in the Extractives Industry
    • Attachment D: Taxation Guidelines for Worldwide Decommissioning
    • Attachment E: Note on Selected Treaty Issues in Relation to Extractive Industries
  • Note by the Subcommittee on Exchange of Information ((E/C.18/2014/CRP.4)
  • Secretariat Note: Proposed United Nations Code of Conduct on Cooperation in Combating International Tax Evasion (E/C.18/2014/CRP.5)
  • Progress report on the work of the Subcommittee on Negotiation of Tax Treaties – Practical Issues (E/C.18/2014/CRP.6)
  • United Nations Capacity Development Programme on International Tax Cooperation Progress Report (E/C.18/2014/CRP.7)
  • Note from the Coordinator of the Subcommittee on Tax Treatment of Services: Draft Article and Commentary on Technical Services (E/C.18/2014/CRP.8)
  • Proposed Changes to the UN Model Tax Convention Dealing with the Cyber-Based Services (E/C.18/2014/CRP.9)
  • Article 23 A and 23 B of the UN Model – Conflicts of qualification and interpretation (E/C.18/2014/CRP.10)
  • Article 5: the meaning of “the same or a connected project” (E/C.18/2014/CRP.11)
  • Responses to questionnaire for developing countries from the UN Subcommittee on Base Erosion and Profit Shifting (E/C.18/2014/CRP.12)
  • Article 13 (CAPITAL GAINS): the practical implications of paragraph 4 (E/C.18/2014/CRP.13)
  • New Provision for U.N. Model to Address Application of Tax Treaties to Payments through Hybrid Entities (E/C.18/2014/CRP.14)
  • Subcommittee on Article 9 (Associated Enterprises): Transfer Pricing (E/C.18/2014/CRP.15)
  • Comments on Article 23A(4) of OECD Model (E/C.18/2014/CRP.16)

Past sessions are available on the UN website:

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Transfer Pricing Chief Economist, RBRT Inc.
514-742-8086; robert.robillard « at » localhost
www.localhost

About RBRT Inc.: click here / (en français ici)

RBRT Inc. is all about transfer pricing. We specialize in transfer pricing, tax treaties and other international tax matters. Our services include transfer pricing documentation (transfer pricing policies and procedures, BEPS and C-doc), transfer pricing dispute resolution, tax treaty matters including double tax relief, tax treaty-based returns and waivers, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek independent tax advice and tax counsel from RBRT Inc. as required.