Skip to Content | Skip to Navigation

Documents on International Cooperation in Tax Matters

 

Background papers - United Nations Model Tax Convention update

2011

17 August 2011 Note by the Secretariat on "Country observations, reservations and positions: relevance to the United Nations Model Tax Convention" (E/C.18/2011/4)
17 August 2011 Note by the Secretariat on "Ad hoc expert group meeting on the 2011 update of the United Nations Model Tax Convention" (E/C.18/2011/3)

2010

11 October 2010 United Nations Model Tax Convention Update (E/C.18/2010/CRP.1)
3 August 2010

Note by the Secretariat on "Issues relating to article 14 of the United Nations Model Convention" (E/C.18/2010/4)

2009

14 October 2009 Note Provided by the Coordinator of the Working Group on "General Issues in the Review of Commentaries" (E/C.18/2009/CRP.5) (Advance unedited version)
6 August 2009 Note by the Secretariat on "Recent work of the Organization for Economic Cooperation and Development on the attribution of profits to permanent establishments: implications for the United Nations Model Double Taxation Convention between Developed and Developing Countries" (E/C.18/2009/2)

2008

17 October 2008 Note by the coordinator of the working group on "Commentaries of the UN Model Convention: Revision of the Commentaries of the UN Model Convention" (E/C.18/2008/CRP.1)

2007

2 November 2007 Revision of the commentaries of the UN Model Convention (E/C.18/2007/CRP.8/Rev.1)
30 October 2007 Corrigendum to the proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2007/CRP.3/Corr.1)
18 October 2007 Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2007/CRP.3)
9 October 2007 Note by the Secretariat on "Citation of the OECD Model Tax Convention by the United Nations Model Tax Convention" (E/C.18/2007/CRP.13)

Background papers - Article 13: capital gains

2010

3 August 2010 Note by the Subcommittee on Capital Gains on "Paragraphs 4 and 5 of article 13 of the United Nations Model Tax Convention, and relevant commentary" (E/C.18/2010/3)

Background papers - Assistance in the collection of taxes (Article 27) and its commentary

2007

25 October 2007 Assistance in the collection of taxes (Article 27) and its commentary (E/C.18/2007/CRP.16)

2006

13 October 2006 Article 27 (Assistance in the collection of taxes) and its Commentary (E/C.18/2006/3)

2005

15 November 2005 Assistance in the collection of taxes (E/C.18/2005/3)

Background papers - Definition of permanent establishment

2010

5 August 2010 Note by the Working Group on Definition of Permanent Establishment on "Proposed new commentary on article 5: paragraphs 15.14 to 15.37" (E/C.18/2010/6)
5 August 2010 Note by the Working Group on Definition of Permanent Establishment on "Proposed new Commentary on Article 5: paragraphs 1 to 15.13" (E/C.18/2010/5)

2009

12 October 2009

Note by the Secretariat on "Definition of Permanent Establishment: Proposed Amendments" (E/C.18/2009/CRP.1)

2008

17 October 2008 Note by the Coordinator of the Subcommittee on Definition of Permanent Establishment: finalised amendments to current Commentary on article 5 - permanent establishment (E/C.18/2008/CRP.10)
October 2008 Proposal for Amendments of the United Nations Model Double Taxation Convention between Developed and Developing Countries: Further Issues Relating to Permanent Establishment (E/C.18/2008/CRP.3)
17 October 2008

Conference Note on "Comments on the Proposal for Amendments of the United Nations Model Double Taxation Convention between Developed and Developing Countries: Further Issues Relating to Permanent Establishment" (E/C.18/2008/CRP.1/Add.1)

2007

9 October 2007 Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries: Further Issues Relating to Permanent Establishment (E/C.18/2007/CRP.4)

2006

22 August 2006 Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2006/4)

2005

2 November 2005 Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2005/5)

Background papers - Dispute resolution

2010

8 October 2010 Guide to the Mutual Agreement Procedure under Tax Treaties (E/C.18/2010/CRP.2/Add.1)
6 October 2010 Report by the Subcommittee on Dispute Resolution: Arbitration as an Additional Mechanism to improve the mutual Agreement Procedure (E/C.18/2010/CRP.2)

2008

17 October 2008 Subcommittee on Dispute Resolution: Background Note on "Resolving issues that prevent a mutual agreement: Supplementary mechanisms for dispute resolution" - Addendum A Guide to the Mutual Agreement Procedure under the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2008/CRP.6/Add.1)
17 October 2008 Subcommittee on Dispute Resolution: Background Note on "Resolving issues that prevent a mutual agreement: Supplementary mechanisms for dispute resolution" (E/C.18/2008/CRP.6)

2007

22 October 2007 Dispute Resolution (E/C.18/2007/CRP.7)

2006

17 October 2006 Dispute resolution/arbitration in tax treaty disputes (E/C.18/2006/8)

2005

5 December 2005 Revision of the United Nations Model Resolution of Tax Treaty Disputes (E/C.18/2005/3/Add.1)

Background papers - Exchange of information

2008

16 October 2008 Corrigendum to the note by the Coordinator of the Subcommittee on "Exchange of Information: proposed revised article 26 (Exchange of information) and proposed revised commentary (2008) on article 26 (paras.1-3)" (E/C.18/2008/3/Corr.1)
16 October 2008 Note by the Coordinator of the Subcommittee on "Exchange of Information: proposed revised commentary (2008) on article 26 (paras.4-6) and proposed code of conduct on cooperation in combating international tax evasion" (E/C.18/2008/3/Add.1/Corr.1)
11 August 2008 Note by the Coordinator of the Subcommittee on "Exchange of Information: proposed revised commentary (2008) on article 26 (paras. 4-6) and proposed code of conduct on cooperation in combating international tax evasion" (E/C.18/2008/3/Add.1)
11 August 2008 Note by the Coordinator of the Subcommittee on "Exchange of Information: proposed revised article 26 (Exchange of information) and proposed revised commentary (2008) on article 26 (paras. 1-3)" (E/C.18/2008/3)

2007

25 October 2007 Proposed general considerations and commentary prepared by the Interim Coordinator of the Subcommittee on Exchange of Information on "Proposed commentary on article 26 (proposed 2007) of the United Nations Model Double Taxation Convention between Developed and Developing Countries" (Comparison of Convener’s 2007 Draft to 2001 Commentary) (E/C.18/2007/CRP.15)
21 August 2007 Proposed commentary on paragraphs 4 to 7 and the inventory of exchange mechanisms, prepared by the Interior Coordinator of the Subcommittee on Exchange of Information on "Proposed commentary on article 26" (E/C.18/2007/11)
21 August 2007 Proposed general considerations and commentary on paragraphs 1-3 prepared by the Interim Coordinator of the Subcommittee on Exchange of Information on "Proposed commentary on article 26 (proposed 2007) of the United Nations Model Double Taxation Convention between Developed and Developing Countries" (E/C.18/2007/10)
21 August 2007 Note by the Interim Coordinator of the Subcommittee on Exchange of Information on "Exchange of information" (E/C.18/2007/5)

2006

8 September 2006 Revision of the wording of article 26 of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2006/6)
1 September 2006 Revision of the wording of Article 26 of the UN Model Convention (E/C.18/2006/6/Add.2) (Advance unedited version)
1 September 2006 Work on exchange of information and conclusion (E/C.18/2006/6/Add.1) (Advance unedited version)

2005

15 November 2005 OECD’s work on improving exchange of information (E/C.18/2005/10/Add.2)
11 November 2005 Report of the Ad Hoc Group of Experts Meeting on Exchange of Information (Revision of Article 26 of the United Nations Model Double Taxation Convention between Developed and Developing Countries) (E/C.18/2005/10/Add.1)
4 October 2005 Proposed revision of article 26, Exchange of information, of the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2005/10)

Background papers - Improper use of treaties / Treaty abuses and Treaty shopping

2008

17 October 2008 Note by the Coordinator of the Subcommittee on "Improper use of treaties: Proposed amendments" (E/C.18/2008/CRP.2)

2007

22 October 2007 Improper use of treaties (E/C.18/2007/CRP.2 English, E/C.18/2007/CRP.2 Spanish)

2006

16 October 2006 Supplementary Note to Treaty Abuse and Treaty Shopping (E/C.18/2006/2) (E/C.18/2006/2/Add.1)
16 October 2006 Treaty Abuse and Treaty Shopping (E/C.18/2006/2) (Advance Unedited Version)

2005

15 November 2005 Abuse of tax treaties and treaty shopping (E/C.18/2005/2)

Background papers - Tax treatment of services

2010

13 October 2010 Note by the Secretariat: Additional Note by Mr. Brian Arnold on the Tax Treatment of Services (E/C.18/2010/CRP.7/Add.1)
11 October 2010 Note on the Taxation Services under the United Nations Model Tax Convention (E/C.18/2010/CRP.7)

2009

15 October 2009 Note Provided by the Coordinator of the Subcommittee on Article 14 and the Tax Treatment of Services (E/C.18/2009/CRP.4)

Background papers - Treatment of Islamic financial instruments

2008

5 September 2008 Note by the Working Group on Treatment of Islamic Financial Instruments on "Treatment of Islamic financial instruments under the United Nations Model Double Taxation Convention between Developed and Developing Countries" (E/C.18/2008/4/Corr.1)
6 August 2008 Note by the Working Group on Treatment of Islamic Financial Instruments on "Treatment of Islamic financial instruments under the United Nations Model Double Taxation Convention between Developed and Developing Countries" (E/C.18/2008/5)

2007

21 August 2007 Note by the Working Group on Treatment of Islamic Financial Instruments on "Treatment of Islamic financial instruments under the United Nations Model Double Taxation Convention between Developed and Developing Countries" (E/C.18/2007/9)

2006

1 September 2006 Treatment of Islamic financial instruments under the United Nations Model Double Taxation Convention between Developed and Developing Countries (E/C.18/2006/9)

Background papers - Transfer pricing: practical manual for developing countries

2011

October 2011

Practical Manual on Transfer Pricing for Developing Countries (October 2011 Working Drafts)

17 August 2011

Note by the Secretariat on "Report on the informal meeting on practical transfer pricing issues for developing countries" (E/C.18/2011/5)

31 May 2011

Practical Manual on Transfer Pricing for Developing Countries:

2010

11 October 2010

Practical Manual on Transfer Pricing for Developing Countries (E/C.18/2010/CRP.4)

2009

18 August 2009 Note by the Secretariat on "Transfer Pricing Practical Manual for Developing Countries" (E/C.18/2009/5)

Background papers - Revision of the Manual for the Negotiation of Bilateral Tax Treaties

2010

12 October 2010

Secretariat Note on Revision of the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (E/C.18/2010/CRP.10)

Accompanying draft Sections of the Manual:

2009

12 October 2009

Note Provided at the Request of the Coordinator of the Subcommittee on Revision of the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (E/C.18/2009/CRP.3)

2008

20 October 2008 Addendum to the note by the coordinator of the working group on "Revision of the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries" (E/C.18/2008/CRP.5/Add.2)
20 October 2008 Addendum to the note by the coordinator of the working group on "Revision of the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries" (E/C.18/2008/CRP.5/Add.1)
20 October 2008

Note by the coordinator of the working group on "Revision of the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries" (E/C.18/2008/CRP.5)

2007

2 November 2007 Revision of the UN Manual for the negotiation of tax treaties between developed and developing countries (E/C.18/2007/CRP.6)

2006

12 October 2006

Manual for the negotiation of tax treaties between developed and developing countries

Background papers - Capacity building

2010

18 October 2010 Update on Work of Subcommittee on Capacity Building (E/C.18/2010/CRP.11/Add.1)
11 October 2010 Overview of Cooperation on Capacity Building in Taxation (E/C.18/2010/CRP.11)

2009

7 August 2009 Tax treaty process for developing countries (E/C.18/2009/3)

Background papers - New and emerging issues

2010

22 October 2010 Tax Cooperation on Climate Change (E/C.18/2010/CRP.12)

Background papers - Other issues

2011

17 August 2011

Provisional agenda (E/C.18/2011/1) and organization of work (E/C.18/2011/2)

2010

13 October 2010 Secretariat Note on Agenda Item - Use of Tax Incentives in Attracting Foreign Direct Investment (E/C.18/2010/CRP.13)
12 October 2010 Concept of beneficial Ownership: Discussion of Key Issues and Proposals for changes to the UN Model Commentary (E/C.18/2010/CRP.9)
3 August 2010 Provisional agenda (E/C.18/2010/1) and organization of work (E/C.18/2010/2)

2009

12 October 2009 Note by the Secretariat on "Proposed Code of Conduct on Cooperation in Combating International Tax Evasion" (E/C.18/2009/CRP.2)
10 August 2009 Note by the Secretariat on "Outcomes of recent conferences relevant to the Committee of Experts" (E/C.18/2009/4)
6 August 2009 Provisional agenda and organization of work (E/C.18/2009/1)

2008

17 October 2008 Addendum to the Note by the Coordinator of the Subcommittee on Improper Use of treaties: Proposed amendments (E/C.18/2008/CRP.2/Add.1)
17 October 2008 Revised tentative programme of work (E/C.18/2008/CRP.9)
5 September 2008 Provisional agenda and organization of work (E/C.18/2008/1)
21 August 2008 Note by the Secretariat on "Follow-up International Conference on Financing for Development to Review the Implementation of the Monterrey Consensus: tax matters" (E/C.18/2008/2)

2007

26 October 2007 Note by the Interim Coordinator of the Subcommittee on Exchange of Information on "United Nations Code of Conduct on Cooperation in Combating International Tax Evasion and Avoidance" (E/C.18/2007/CRP.17)
22 October 2007 Report of the Expert Group Meeting on “Tax Aspects of Domestic Resource Mobilisation – A Discussion of Enduring and Emerging Issues” (E/C.18/2007/CRP.14)
22 October 2007 Draft Guidelines Prepared by the Staff of the International Tax Dialogue Steering Group on "Tax treatment of donor-financed projects" (E/C.18/2007/CRP.12)
8 August 2007 Provisional agenda and organization of work (E/C.18/2007/1) and (E/C.18/2007/1/Corr.1)

2006

17 October 2006 Tax treatment of donor-financed projects (E/C.18/2006/5)

1 September 2006

Developing a Code of Conduct on Promoting Tax Compliance (E/C.18/2006/6/Add.3) (Advance unedited version)
1 September 2006 Provisional agenda and organization of work (E/C.18/2006/1)

2005

28 November 2005 Application of the United Nations Model to payments received under certain financial instruments (E/C.18/2005/4)
22 November 2005 Tax cooperation and cross-border tax crime: Roles of international organization and potential roles for the United Nations (E/C.18/2005/10/Add.3)
22 November 2005 Tax aspects of donor-financed projects (E/C.18/2005/9)
16 November 2005 Proposed agenda and draft programme of work for the first session of the Committee of Experts on International Cooperation in Tax Matters (E/C.18/2005/1)

ECOSOC resolutions & decisions

2013

24 July 2013 ECOSOC resolution on (E/RES/2013/24) "Committee of Experts on International Cooperation in Tax Matters"
23 July 2013 Draft ECOSOC decision (E/2013/L.39) on "Dates and provisional agenda for the ninth session of the Committee of Experts on International Cooperation in Tax Matters"
28 June 2013 Note by the Secretary-General (E/2013/9/Add.10) on "Appointment of 25 members to the Committee of Experts on International Cooperation in Tax Matters"
10 July 2013 Draft ECOSOC resolution (E/2013/L.22) on "Committee of Experts on International Cooperation in Tax Matters"
12 June 2013 Draft ECOSOC resolution (E/2013/L.9) on "Committee of Experts on International Cooperation in Tax Matters"

2012

27 July 2012 ECOSOC resolution 2012/33 on "Committee of Experts on International Cooperation in Tax Matters"
25 July 2012 Draft ECOSOC resolution (E/2012/L.30) on "Committee of Experts on International Cooperation in Tax Matters"
23 July 2012 Draft ECOSOC resolution (E/2012/L.20) on "Committee of Experts on International Cooperation in Tax Matters"
23 July 2012 Draft ECOSOC decision (E/2012/L.19) on "Dates and draft agenda for the eighth session of the Committee of Experts on International Cooperation in Tax Matters"

2011

27 July 2011 ECOSOC resolution 2011/23 on "Committee of Experts on International Cooperation in Tax Matters"
27 July 2011 ECOSOC decision 2011/253 on "Venue and dates of and provisional agenda for the seventh session of the Committee of Experts on International Cooperation in Tax Matters"

2010

23 July 2010 ECOSOC resolution 2010/33 on "Committee of Experts on International Cooperation in Tax Matters" (E/2010/INF/2/Add.1, page 152)
23 July 2010 ECOSOC decision 2010/257 on "Venue and dates of and provisional agenda for the sixth session of the Committee of Experts on International Cooperation in Tax Matters" (E/2010/INF/2/Add.1, page 204)
20 July 2010 Statement on programme budget implications of draft resolution E/2010/L.10 (E/2010/L.28)
2 July 2010 Draft ECOSOC resolution (E/2010/L.10) on "Committee of Experts on International Cooperation in Tax Matters"

2009

31 July 2009 ECOSOC decision 2009/265 on "Committee of Experts on International Cooperation in Tax Matters" (E/2009/INF/2/Add.1, page 156)

2008

24 July 2008 ECOSOC resolution 2008/16 on "Committee of Experts on International Cooperation in Tax Matters" (E/2008/INF/2/Add.1, page 44)

2007

4 October 2007 ECOSOC resolution 2007/39 on "Committee of Experts on International Cooperation in Tax Matters" (E/2007/INF/2/Add.2, page 5)
27 July 2007 ECOSOC decision 2007/267 on "Report of the Committee of Experts on International Cooperation in Tax Matters" (E/2007/INF/2/Add.1, page 156)

2006

28 July 2006 ECOSOC resolution 2006/48 on "Committee of Experts on International Cooperation in Tax Matters" (E/2006/INF/2/Add.1, page 160)

2004

11 November 2004 ECOSOC resolution 2004/69 on "Committee of Experts on International Cooperation in Tax Matters" (E/2004/INF/2/Add.3, page 14)

Reports of the Secretary-General

2013

9 May 2013

Report of the Secretary-General on "Further progress in strengthening the work of the Committee of Experts on International Cooperation in Tax Matters" (E/2013/67)

2012

E/2010/45
E/C.18/2010/7

Report on the sixth session of the Committee of Experts on International Cooperation in Tax Matters (18-22 October 2010)

2011

18 March 2011

Report of the Secretary-General on "Strengthening of institutional arrangements to promote international cooperation in tax matters, including the Committee of Experts on International Cooperation in Tax Matters" (E/2011/76)

2008

6 March 2008

Report of the Secretary-General on "Financing of the Committee of Experts on International Cooperation in Tax Matters" (E/2008/4)

Reports of the Committee of Experts on International Cooperation in Tax Matters

2013

(E/2013/45-E/C.18/2013/6)

Report on the ninth session of the Committee of Experts on International Cooperation in Tax Matters (21-25 October 2013)

2012

E/2012/45-E/C.18/2012/6

Report on the eighth session of the Committee of Experts on International Cooperation in Tax Matters (15-19 October 2012)

2011

E/2011/45-E/C.18/2011/6

Report on the seventh session of the Committee of Experts on International Cooperation in Tax Matters (24–28 October 2011)

2010

E/2010/45
E/C.18/2010/7

Report on the sixth session of the Committee of Experts on International Cooperation in Tax Matters (18-22 October 2010)

2009

E/2009/45 (SUPP)
E/C.18/2009/6 (SUPP)

Report on the fifth session of the Committee of Experts on International Cooperation in Tax Matters (19-23 October 2009)

2008

E/2008/45
E/C.18/2008/6
Report on the fourth session of the Committee of Experts on International Cooperation in Tax Matters (20-24 October 2008)

2007

E/2007/45
E/C.18/2007/19
Report on the third session of the Committee of Experts on International Cooperation in Tax Matters (29 October-2 November 2007)

2006

E/2006/45
E/C.18/2006/10

Report on the second session of the Committee of Experts on International Cooperation in Tax Matters (30 October-3 November 2006)

2005

E/2005/45
E/C.18/2005/11

Report on the first session of the Committee of Experts on International Cooperation in Tax Matters (5-9 December 2005)

For more information, please contact: Michael Lennard, Secretary,
Committee of Experts on International Cooperation in Tax Matters
Email: taxffdoffice@un.org

 
 
 

Financing for Development Office, 2 U.N. Plaza (DC2-2170), New York, N.Y. 10017
Email: ffdoffice@un.org, Fax: 212-963-0443, Website: www.un.org/esa/ffd