Seventh Session of the Committee of Experts on International Cooperation in Tax Matters

Background Information

• 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)
• Note by the Secretariat on "Country observations, reservations and positions: relevance to the United Nations Model Tax Convention" (E/C.18/2011/4)
• Note by the Secretariat on "Special Meeting on Transfer Pricing Issues for Developing Countries – Secretariat Report" (E/C.18/2011/5)
• Opening statement by Alexander Trepelkov, Director, Financing for Development Office, DESA

Conference room papers (CRP)
Please note that for logistical reasons we will most likely be able to supply only Committee Members with the larger conference room paper (CRP) documents in Geneva, including the draft Update of the UN Model Double Taxation Convention and other documents over 40 pages long. We urge other participants to bring electronic or paper copies of such documents to the Annual Session.

• Proposed update of United Nations Model Tax Convention:
  • E/C.18/2011/CRP.1 - Introduction
  • E/C.18/2011/CRP.2
  • E/C.18/2011/CRP.2/Add.1
  • E/C.18/2011/CRP.2/Add.2
  • E/C.18/2011/CRP.2/Add.3
• Proposed new Article 25 Commentary E/C.18/2011/CRP.3 (clean copy; marked up copy)
• Guide to the Mutual Agreement Procedure under Tax Treaties E/C.18/2011/CRP.4 (clean copy; marked up copy)
• Tax Treatment of Services - E/C.18/2011/CRP.7
• Capacity Building - E/C.18/2011/CRP.8
• Tax Cooperation and Climate Change - E/C.18/2011/CRP.9
• Note on the Revision of the Manual for Negotiation of Bilateral Tax Treaties:
  • E/C.18/2011/CRP.11 - Introduction to International Double Taxation and Tax Evasion and Avoidance
  • E/C.18/2011/CRP.11/Add.1 - International Tax Evasion and Avoidance
  • E/C.18/2011/CRP.11/Add.2 - Suggestions Relating to the Application of the Articles of the UN Model Convention and Procedural Aspects of Tax Treaty Negotiations
  • E/C.18/2011/CRP.11/Add.3 - Basic Approches to Tax Treaty Negotiation
  • E/C.18/2011/CRP.11/Add.4 - Dispute Resolution Mutual Agreement Procedure
  • E/C.18/2011/CRP.11/Add.5 - Appendix for Special Consideration Items
  • E/C.18/2011/CRP.11/Add.6 - International Tax Websites
  • E/C.18/2011/CRP.11/Add.7 - Questionnaire on the Manual for Negotiation of Bilateral Tax Treaties

Please note that we are advised that scheduled papers E/C.18/2011/CRP.5 (beneficial ownership), E/C.18/2011/CRP.6 (capital gains) and E/C.18/2011/CRP.12 (Further issues) are not considered to be needed by those dealing with these subjects and will not form part of the annual session's documentation.

• Working drafts of the Practical Manual on Transfer Pricing for Developing Countries