Overview

The UN Model Tax Convention: Recent Developments provides an in-depth analysis of the United Nations Model Double Taxation Convention, a key instrument in international tax law. Designed as a counterpart to the OECD Model, the UN Model responds to the specific concerns of developing countries, aiming to ensure a more equitable allocation of taxing rights between source and residence jurisdictions. This book examines how the UN Model continues to evolve in response to the changing global tax environment. It explores recent amendments and emerging trends that reflect broader economic transformations, including the rise of the digital economy, the globalization of trade and investment, and increasing calls for tax fairness. Special attention is given to the Model's emphasis on source-based taxation that is critical in supporting the fiscal sovereignty of developing nations. With contributions from leading academics and practitioners offering both theoretical and practical perspectives, this edited volume provides clear and accessible guidance on such taxation issues and topics as the following: treatment of income arising from extractives and other natural resources; taxation of income from international shipping and international air transport; taxation of income from cross-border insurance activities; the future of taxing income from cross-border services; taxation of capital gains on shareholdings; cross-border taxation issues involving remote workers; Fast-Track Instrument; and general 'subject-to-tax' rule. Through critical analyses and comparative perspectives, this book offers insights into the UN Model's role in shaping a more balanced and inclusive international tax order. It addresses both the technical and policy dimensions of recent changes, making it an essential resource for tax policymakers, legal practitioners, academics, and international organizations engaged in treaty making and global tax governance. The chapters are revised and expanded versions of the contributors' works presented at the 32nd Viennese Symposium on International Tax Law held on 6 June 2025 at WU Vienna University of Economics and Business. Each chapter offers an in-depth analysis of a particular topic referencing the most recent scientific research.

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