The UN tax
committee members have submitted a proposal arguing that payments for software
should be included in the definition of royalties for the purposes of the model
double tax convention.
The UN
commmittee has published a discussion draft of possible changes to the UN model
double tax convention between developed and developing countries so that the
definition of royalties in article 12(3) would be amended to include payments
for the use of computer software. This would mean that taxing rights would be
allocated to the state where the user is
At present, the
draft is proposed by some member of the committee, but opposed by others.
Arguments on both sides are set out in the discussion draft.
It is open for
public comment until 2 October. The proposal will then be considered by the tax
committee at the 21st session scheduled for the end of October 2020.
The UN tax
committee members have submitted a proposal arguing that payments for software
should be included in the definition of royalties for the purposes of the model
double tax convention.
The UN
commmittee has published a discussion draft of possible changes to the UN model
double tax convention between developed and developing countries so that the
definition of royalties in article 12(3) would be amended to include payments
for the use of computer software. This would mean that taxing rights would be
allocated to the state where the user is
At present, the
draft is proposed by some member of the committee, but opposed by others.
Arguments on both sides are set out in the discussion draft.
It is open for
public comment until 2 October. The proposal will then be considered by the tax
committee at the 21st session scheduled for the end of October 2020.
