(October 7, 2014)

The tenth annual session of the Committee of Experts on International Cooperation in Tax Matters will be held from 27 to 31 October 2014 at the Palais des Nations in Geneva.

The meeting will a.o. discuss issues related to the next update of the United Nations Model Double Taxation Convention between Developed and Developing Countries, including a.o.: 

• various issues related to the application of treaty rules to hybrid entities (Article 4);
• the concept of “permanent establishment”, the meaning of “connected projects” and physical presence issues (Article 5);
• the meaning of “auxiliary activities” under Article 8 (Transportation);
• Update of the Commentary to Article 9 (Associated Enterprises);
• Article 12 on Royalties;
• conflicts of qualification, and conflicts of interpretation (Article 23 methods for elimination of double taxation); and
• Article 26 on Exchange of Information.

The Committee will also discuss cross-cutting issues under the UN Model, such as taxation of services.

Other issues on the agenda of the session include a.o.:  

• work towards the next update of the United Nations Practical Manual on Transfer Pricing for Developing Countries;
• the draft Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries;
• taxation of extractive industries;
• Base Erosion and Profit-Shifting (BEPS) and its consequences for developing countries; and
• cooperative compliance and corporate governance in tax matters.

The Annual Session of the UN Committee of Experts on International Tax Cooperation in Tax Matters (‘The Committee’) is a closed meeting, rather than a public one. However, to the extent practicable, the Committee allows observers. Interested parties can therefore register as observers to the 2014 Committee Session. The registration closes on October 15, 2014.

For further information click here to be forwarded to the announcement as made by the United Nations with respect to the Tenth Session of the Committee of Experts on International Cooperation in Tax Matters as published on the website of the UN, which will open in a new window.  

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