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Brian J. Arnoldof Chile as coordinator was established in 2009. Over the course ofthe next few years, the Committee and the Subcommittee continuedto discuss the taxation of services. They also examined a studyby the International Bureau of Fiscal Documentation (IBFD) on theprovisions of recent tax treaties dealing with income from services 72and papers by the author of the present chapter analysing the provisionsof the United Nations Model Convention dealing with servicesand identifying options for change. 73 In 2011, at its seventh session,the Committee decided to work on the taxation of fees for technicalservices as a matter of priority. In 2012, at its eighth session, theCommittee examined and debated a wide-ranging list of options todeal with income from technical services and decided to proceedwith work on a new article covering such income to be added to theUnited Nations Model Convention. In 2013, at its ninth session, theCommittee discussed three options concerning the scope of a newarticle dealing with income from technical services, as follows:‣ ¾ Option 1: a broad provision applicable to services performedinside and outside the source country, with no threshold forsource country taxation and taxation on a gross basis;‣ ¾ Option 2: a provision applicable only to services rendered in thesource country, with no threshold and taxation on a gross basisat a limited rate;72See W. Wijnen, J. de Goede and A. Alessi, “The Treatment of Servicesin Tax Treaties,” (2012) Vol. 66, No. 1 Bulletin for International Taxation.73See “Note on the Taxation of Services under the United Nations ModelTax Convention,” 11 October 2010, presented at the sixth session of the UnitedNations Committee of Experts (18 – 22 October 2010), E/C.18/2010/CRP.7,available at http://www.un.org/esa/ffd/wp-content/uploads/2014/10/6STM_NoteTaxationOfServices.pdf; “Additional Note on the Taxation of Servicesunder the United Nations Model Tax Convention,” 13 October 2010, presentedat the sixth session of the United Nations Committee of Experts(18 – 22 October 2010), E/C.18/2010/CRP.7/Add.1, available at http://www.un.org/esa/ffd/wp-content/uploads/2014/10/6STM_CRP7_Add1.pdf; and“Note on the Taxation of Fees for Technical and Other Services under theUnited Nations Model Convention,” 2 August 2012, presented at the eighthsession of the United Nations Committee of Experts (15 – 19 October2012), E/C.18/2012/4, available at http://www.un.org/ga/search/view_doc.asp?symbol=E/C.18/2012/4&Lang=E.90

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