United Nations: 2017 UN Model Double Taxation Convention released

Treaty news

2017 UN Model Double Taxation Convention released
On 17 May 2018, the United Nations released the text of the 2017 United Nations Model Double Taxation Convention between Developed and Developing Countries. The following articles were updated: article 1 (persons covered), article 4 (resident), article 5 (permanent establishment), article 10 (dividends), article 12A (fees for technical services), article 13 (capital gains), articles 23 A and 23 B (tax relief). A new article 29 was added (limitation on benefits rule) in addition to a general anti avoidance rule (principal purpose test) which is similar to the one included under article 29 of the 2017 OECD Model Convention.​

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