In accordance with ECOSOC decision 2015/214 of 9 June 2015, the eleventh session of the Committee of Experts on International Cooperation in Tax Matters was held from 19 to 23 October 2015 at the Palais des Nations in Geneva.
The meeting discussed, inter alia, the next update of the United Nations Model Double Taxation Convention between Developed and Developing Countries, including issues related to the application of treaty rules to hybrid entities (Article 1), the meaning of “connected projects” (Article 5), the meaning of “auxiliary activities” under Article 8 (Transportation) and Article 12 on Royalties. The Committee also discussed cross-cutting issues under the UN Model, such as base erosion and profit shifting and the taxation of services.
Other issues on the agenda of the session included 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, the taxation of the extractive industries, capacity development and arbitration issues for developing countries.
- Informal Secretariat annotated and updated agenda as of 14 October 2015
- Provisional agenda and organization of work (E/C.18/2015/1)
- Note by the Secretariat on “Addis Ababa Action Agenda: outcomes related to the work of the Committee of Experts on International Cooperation in Tax Matters” (E/C.18/2015/2)
- Note by the Secretariat on “New provision for the United Nations Model Double Taxation Convention between Developed and Developing Countries to address the application of tax treaties to payments made through hybrid entities” (E/C.18/2015/3)
- Note by the Secretariat on “Capacity development programme in international
tax cooperation” (E/C.18/2015/4)
- Note by the Secretariat on “Capacity development programme in international tax cooperation” (E/C.18/2015/5)
- Practical Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (Presentation)
Conference room papers (CRP)
- Subcommittee on Article 9 (Associated Enterprises): Transfer Pricing (E/C.18/2015/CRP.1)
- Subcommittee on Extractive Industries Taxation Issues for Developing Countries(E/C.18/2015/CRP.2) (Presentation)
- Attachment 1: Overview Note on Extractive Industries Taxation Issues
- Attachment 2: Note on Capital Gains Taxation and Taxation of Indirect Asset Transfers
- Attachment 3: Note on Selected Treaty Issues in Relation to the Extractive Industries (Presentation)
- Attachment 4: Guidance Note on the Tax Treatment of Decommissioning for the Extractive Industries (Presentation)
- Attachment 5: Overview Note on Value-Added Tax in the Extractive Industries
- Attachment 6: Draft Outline of Guidance Note on Negotiation and Renegotiation of Contracts
- Attachment 7: Draft Outline of Guidance Note on Permanent Establishment Issues for the Extractive Industries
- Possible Joint Actions by the Subcommittee on Article 9 (Associated Enterprises): Transfer Pricing and the Subcommittee on Extractives Industries Taxation Issues for Developing Countries (E/C.18/2015/CRP.3) (Presentation)
- United Nations Code of Conduct on Cooperation in Combating International Tax Evasion (E/C.18/2015/CRP.4) (clean copy; marked up copy)
- Revised Draft Article and Commentary UN Model Tax Convention – Fees for Technical and Other Services (E/C.18/2015/CRP.5) (Presentation)
- The character and purpose of Article 12 with reference to “industrial, commercial and scientific equipment” and software-payment related issues containing non-substantive amendments (E/C.18/2015/CRP.6) (Presentation: UN Model vs OECD Model)
- Article 12 (Royalties) (E/C.18/2015/CRP.7) (Presentation: Aim of Royalties)
- Article 5: the meaning of “the same or a connected project” (E/C.18/2015/CRP.9) (clean copy; marked up copy) (Presentation: Purpose of suggested changes to the Commentary on Article 5) (Presentation: Minority view – physical presence)
- United Nations Capacity Development Programme on International Tax Cooperation, Progress Report (E/C.18/2015/CRP.10) (Presentation)
- Subcommittee on Base Erosion and Profit Shifting for Developing Countries (E/C.18/2015/CRP.11) Updated Survey on Developing Countries’ Reaction to the G20/OECD BEPS Project (Presentation BEPS) (Presentation Handbook: Protecting the Tax Base)
- Intra-Group Services (E/C.18/2015/CRP.12)
- Article 8 (Shipping, inland waterways transport and air transport) (Presentation)
Please note that registration for the Eleventh Session of the Committee of Experts on International Cooperation in Tax Matters is now closed.
Registered participants should retain a hard copy of their completed registration form and bring it with them when registering with the UN Security in Geneva.