UN Model on the move?

The UN Committee of Experts on International Cooperation in Tax Matters, meeting in Geneva October 30 through November 3, discussed the possible revision of the 2001 United Nations Model Double Taxation Convention Between Developed and Developing Countries. The 2001 UN Model, which followed the previous 1980 UN Model, is still far from the development of its counterpart (the OECD Model) has had in the last decade.

The Provisional agenda and organization of work agenda included treaty abuses, mutual assistance in tax collection, definitions of permanent establishment and interest, taxation of development projects, information exchange, dispute resolution, and revisions of both the UN model income tax treaty and the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries. Read the final report.

Here is a list of the documents posted on the UN website:

1. Treaty Abuse and Treaty Shopping
2. Supplementary Note to Treaty Abuse and Treaty Shopping
3. Assistance in the collection of taxes (Article 27) and its commentary
4. Proposal for amendments to article 5 of the United Nations Model Double Taxation
5. Tax treatment of donor-financed projects
6. Revision of the wording of Article 26 of the UN Model Convention
7. Work on exchange of information and conclusion
8. Revision of the commentaries to Article 26 of the UN Model
9. Developing a Code of Conduct on Promoting Tax Compliance
10. Manual for the negotiation of tax treaties between developed and developing countries
Cover; Part1; Part 2; Part 3; Annex
11. Dispute Resolution/Arbitration in tax treaty disputes
12. Treatment of Islamic financial instruments under the UN Model Double

Click here for the documents made available for the first session held in Geneva from 5-9 December 2005.

Note: Click here for a good article by Bart Kosters (The United Nations Model Tax Convention and Its Recent Developments) on the evolution of the UN Model, namely the differences between the 2001 UN Model and the OECD Model and the UNModel of 2001 compared to the 1980 version.

Pic: the photo is taken from the strange phenomenon of the Death Valley Moving Rocks