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
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
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
2009
| 7 August 2009 |
Tax treaty process for developing countries (E/C.18/2009/3) |
Background papers - New and emerging issues
2010
Background papers - Other issues
2011
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
2012
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
8 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" (Advance unedited version)
|
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
Reports of the Committee of Experts on International Cooperation in Tax Matters
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)
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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)
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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
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)
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For more information, please contact: Michael Lennard, Acting Secretary,
Committee of Experts on International Cooperation in Tax Matters
Email: taxffdoffice@un.org
