Please follow the link to listen to the lecture of Micheal Lennard "Geneva meeting on the UN model convention": Video Lecture 

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Summary of Micheal Lennard’s guest lecture

Report of the Geneva meeting on the UN model convention.

The U.N. tax committee is about financing for development. The Monterrey consensus deals with financing for development. It entails; 

o Domestic resource mobilization; refers to the need to have a sort of tax base.

o FDI is important. A country needs to have a tax system which encourages people to come to your country. It is about finding a balance between earning form foreign investment and attracting business by incorporating low tax rates.

o Systemic issues; developing countries need to have a voice in taxation issues.

This is particularly an issue in transfer pricing. These rules were set by developed countries. These rules need to work better for developing countries.

On committees: 

o A new article on exchange on information is rather similar to the OECD model. It was incorporated as it was felt that this was an important issue for developing countries.

o The major issue in the future -except for transfer pricing- will probably be treatment of services. Later more on this.

o There is a new committee on treatment of emissions permits and clean development.

 On the difference between the UN and the OECD model: 

o The main difference is that, to avoid double taxation both countries usually have a taxing right. One country has to give up, under certain circumstances part of this taxing right. Under the UN model more taxing rights are retained by source countries. With credit or exemption required by the residence country.

o It is not only a developed vs. developing countries matter. Some developed countries sometimes take source perspectives.

o Article 5: Greater source state taxation rights are preserved under the UN model.

o Services: The OECD approach is that really services are no different from goods provision. It should be treated the same way as other business activities. The OECD recently has included an additional possible (minority) provision to tax services without there being a permanent establishment. This is an answer to the concern that some service businesses do not require a fixed place of business.

o The optional provision taxation of services without a traditional PE. It states that “an individual who is present in that other State for a period or periods exceeding the aggregate 183 days in any twelve month periode, and more than 50 percent of the gross revenues attributable to active business activities of the enterprise during this period or periods are derived from the services performed  in that other State through that individual, …”. This relates to worldwide gross revenue for that person. The U.N. is very conscious about the complexity of administration for developing countries. It is hard and costly for them to find out the gross worldwide revenue. This is an example of how hard it is to enforce change in developing countries. In developed countries it is very easy to change or update the law. Developing countries might have skeptical ministers etc. and it is much harder to get rulings out. So for developing countries there is much more complexity to any change in the model.