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Taxation of income from serviceswithholding tax is applied to a percentage of the relevant payment forservices. For example, in the Bolivarian Republic of Venezuela onlyone-half of the gross amount of payments for technical services is subjectto tax at the rate of 34 per cent, resulting in an effective tax rate of17 per cent. 37 Argentina uses this presumptive approach for most typesof income subject to the nominal rate of withholding tax of 35 per cent.Since varying percentages of income are subject to tax, the effective taxrates range from 12.5 per cent to 31.5 per cent. 38India applies a general withholding tax rate of 10 per centalthough the rate increases to 20 per cent if the non-resident serviceprovider does not have a taxpayer identification number. Brazil andthe Bolivarian Republic of Venezuela apply an increased rate of withholdingtax on payments for services made to residents of listed lowtaxjurisdictions.3. An overview of the provisions of the United NationsModel Convention dealing with income from services3.1 IntroductionThis section contains a brief description of all of the provisions ofthe United Nations Model Convention that deal with income fromservices. 39 The purpose of this overview is to provide sufficient backgroundinformation about the provisions to allow the identificationof those of them that potentially permit the erosion of the tax baseof developing countries. The identification of the provisions that areproblematic in this regard is essential in order to properly target37See Rodrigo Castillo Cottin and Ronald Evans Márquez, “Venezuela,”in International Fiscal Association, “Enterprise Services,” in Cahiers de droitfiscal international, supra note 7, at 753.38See Alejandro Almarza, “Argentina,” in International Fiscal Association,“Enterprise Services,” in Cahiers de droit fiscal international, supra note7, at 74 – 76.39The material in this section is based on Brian J. Arnold, “TheTaxation of Income from Services under Tax Treaties: Cleaning Up theMess — Expanded Version,” (2011) Vol. 65, No. 2 Bulletin for InternationalTaxation (online version).63