The counterpart of the United Nations Model Tax Convention, the OECD Model Tax Convention (and its Commentary) was further amended in 2003 and 2005.

In that context, article 5 of the United Nations Model Tax Convention and article 5 of the OECD Model Tax Convention were examined and a comparison was drawn up.

Amendments to the text of the United Nations Model Tax Convention

The amendments to the OECD Model Tax Convention and the Commentary thereon were further evaluated as to whether such amendments should also be reflected, or further improved, in the United Nations Model Tax Convention and Commentary.

The need was felt to analyse the current United Nations Model Tax Convention and propose any amendments deemed opportune.

(a) The wording of article 5 of the text of the United Nations Model Tax Convention should not be amended

By agreeing to adopt the standard on the exchange of information set out in Article 26 of the OECD s Model Tax Convention, Switzerland will now extend administrative assistance to cover all tax offenses, including tax evasion.

Some of the amendments to the OECD Model Tax Convention, however, include a narrowing of the requirements for constituting a permanent establishment.

Model Nuclear Weapons Convention

OECD is currently considering whether in the name of in article 5 (5) of the OECD Model Tax Convention could be interpreted also in an economic sense.

This goes against the perceived objective of the United Nations Model Tax Convention which gives more weight to the source principle, resulting in a wider definition of permanent establishments.

The authors of this proposal are of the opinion that the text of article 5 of the United Nations Model Tax Convention should not be amended or altered in any way.

The 2000 amendments to the Model Tax Convention on Income and on Capital of the Organization for Economic Cooperation and Development (OECD) were as it seems, taken into account in that 2001 amendment.

Two non member countries have taken a contrary position to that of the OECD Commentary in this respect (para. 21 positions on the Commentary to article 5 of the OECD Model Tax Convention).

This amendment is in line with the aims of the United Nations Model Tax Convention and Commentary and it would be beneficial to include it in forthcoming amendments to the United Nations Commentary.

(It should be noted that the OECD Model TIEA is only an exchange of information agreement it is not a comprehensive model income tax treaty.

There would be no inconsistency between the draft convention and the Model Law.

(d) The addition of paragraph 4.5 to the OECD Commentary should be clarified further in that article 5 (3) of the text of the OECD Model Tax Convention is a special rule under the general rule of article 5 (1)

Not only must the amendments to the United Nations Model Tax Convention and or Commentary thereon be beneficial to all States Members of the United Nations, including the developing countries, but such amendments should also facilitate the negotiating parties' coming to an agreement.

In view of this, it is suggested that the following clause similar to article 5 (1) of the OECD Model TIEA be added to the United Nations Model Income Tax Treaty, as paragraph 26 (6)

United Nations (2001). United Nations Model Double Taxation Convention between Developed and Developing Countries. Sales No.

A model for this approach was suggested to be draft article 83 of the draft convention.

On the other hand, the Estonian political system, its flat rate of income tax, and its non welfare state model distinguish it from the Nordic countries and their Nordic model, and indeed from many other European countries.

(1) What is the suitability of a financial mechanism model or type to the Rotterdam Convention? and

Article 2 (1) of the United Nations Model Income Tax Treaty states that (T)his Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities irrespective of the manner in which they are levied .

A seldom mentioned reason is that shale gas development in the US has benefited from important tax incentives a model that Europe has no reason to emulate.

Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries ,

The authors' proposal is that the third sentence read On site planning and supervision of the erection of a building, construction, assembly or installation project are covered by paragraph 3. (The authors are aware that article 5 (3) (a) of the United Nations Model Tax Convention contains a reference to supervisory activities .

Proposed revision of article 26, Exchange of information, of the United Nations Model Double Taxation Convention between Developed and Developing Countries

In that respect, the procedure set out in article 3 of Annex VII to the Convention could serve as a model.

It was important, in his view, to preserve consistency between the draft convention and the UNCITRAL Model Law on Electronic Signatures.

Naturally, many conservative Americans were delighted by the imminent failure of what they saw as Europe s tax and spend model, with its addiction to a costly and inefficient welfare state.

The OECD Model TIEA (article 5 (2) and para. 43 of the Commentary thereon) also provides that a domestic tax interest requirement does not limit the obligation to exchange information.

Noting that the Convention has served as a model for subsequent multilateral and bilateral treaties and other international legislative texts on arbitration,

Tax revenue can be raised without increasing marginal tax rates by limiting the tax subsidies that are built into the current tax code.

A tax called a death tax is regarded very differently from a tax called an inheritance tax, even though the two are really identical.

Previous positions include Director, International Tax Relations, Tax Policy Department Director, Tax Department, Italian Banking Association and Economic Adviser to the Minister of Finance for international tax policy and financial tax issues.

(n) The interpretation of the wording in the name of (article 5 (5) of both the OECD and the United Nations Model Tax Conventions) in an economic sense should not be attempted.

All for One Tax and One Tax for All?

The sponsors of draft resolution A C.1 60 L.53 want to make the Chemical Weapons Convention a model for other future agreements.

Capital tax differences among countries would induce capital to flow from the high tax to the low tax economies. Such tax induced distortions would lead to an inefficient regional allocation of investment and possible tax competition.

a Airstrip includes use tax, landing fee and passenger tax.

The Montreal Protocol example could be considered a possible model for the establishment of Stockholm Convention regional centres in UNEP regional offices that coordinate the efforts of subregional centres and national focal points under the Convention.

The OECD Model TIEA (introduction, para. 3) confirms that (t)he 1998 Report identified the lack of effective exchange of information as one of the key criteria in determining harmful tax practices (emphasis added).

The current United Nations Model Double Taxation Convention between Developed and Developing Countries (and its Commentary) (United Nations, 2001) had last been amended in 2001.