Sixth Session of the Committee of Experts on International Cooperation in Tax Matters
18-22 October 2010, Geneva
In accordance with ECOSOC decision 2010/257 (E/2010/INF/2/Add.1, page 204) of 23 July 2010, the sixth session of the Committee of Experts on International Cooperation in Tax Matters was held in Geneva from 18 to 22 October 2010.
The main objective of the session was to complete the revision of the United Nations Model Double Taxation Convention between Developed and Developing Countries, in accordance with the Committee’s mandate. The session also addressed important issues and proposals in other areas of the work of the Committee, such as for instance "transfer pricing" and capacity building in national tax systems.
Organizational Matters
- Provisional agenda (E/C.18/2010/1)
- Organization of work (with links to presentations)
- UN Journal announcement
- Information Circular for Sixth Session Participants
Outcome
Report on the sixth session of the Committee of Experts on International Cooperation in Tax Matters (E/2010/45 - E/C.18/2010/7)
Registration
Please note that registration has been closed.
Background Information
- Note by the Subcommittee on Capital Gains on paragraphs 4&5 of article 13 and relevant commentary (E/C.18/2010/3)
- Note by the Secretariat on Issues relating to article 14 of the United Nations Model Convention (E/C.18/2010/4)
- 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)
- Paragraphs 15.14 to 15.37 (E/C.18/2010/6)
Conference room papers (CRP)
Please note that for logistical reasons we will most likely be able to supply Committee Members only with the larger conference room paper (CRP) documents in Geneva, including the draft Manual for the Negotiation of Bilateral Tax Treaties and documents over 50 pages long. We urge other participants to bring electronic or paper copies of such documents to the Annual Session.
- United Nations Model Tax Convention update (E/C.18/2010/CRP.1)
- Report by the Subcommittee on Dispute Resolution: Arbitration as an Additional Mechanism to improve the mutual Agreement Procedure (E/C.18/2010/CRP.2)
- Guide to the Mutual Agreement Procedure under Tax Treaties (E/C.18/2010/CRP.2/Add.1)
- Practical Manual on Transfer Pricing for Developing Countries (E/C.18/2010/CRP.4)
- Working Draft on Chapter 1 - An Introduction to Transfer Pricing
- Working Draft on Chapter 2 - Business Framework
- Working Draft on Chapter 2A - The Legal Environment
- Working Draft on Chapter 3 - Capability Building
- Working Draft on Chapter 4 - Traditional Methods
- Working Draft on Chapter 5 - Transactional Profit Methods
- Note on the Taxation of Services under the United Nations Model Tax Convention (E/C.18/2010/CRP.7)
- Note by the Secretariat: Additional Note by Mr. Brian Arnold on the Tax Treatment of Services (E/C.18/2010/CRP.7/Add.1)
- Concept of Beneficial Ownership: Discussion of Key Issues and Proposals for Changes to the UN Model Commentary (E/C.18/2010/CRP.9)
- Secretarial 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:
- Section 1: Basic Approaches
- Section 2: Appendix for Special Consideration Articles
- Section 4: Australia-Mexico Treaty
- Section 5: China-UN Treaty & Brazil-India Treaty
- Section 6: Useful Internet Websites
- Overview of Cooperation on Capacity Building in Taxation (E/C.18/2010/CRP.11)
- Update on Work of Subcommittee on Capacity Building (E/C.18/2010/CRP.11/Add.1)
- Tax Cooperation on Climate Change (E/C.18/2010/CRP.12)
- Secretariat Note on Agenda Item - Use of Tax Incentives in Attracting Foreign Direct Investment (E/C.18/2010/CRP.13)
- Capacity Building Subcommittee questionnaire (Please respond to munyaneza@un.org)
For more information, please contact: Michael Lennard, Acting Secretary,
Committee of Experts on International Cooperation in Tax Matters
Email: taxffdoffice@un.org