UN Tax Committee approves Article 12B on income

Digitalisation of business models has given rise to significant challenges for international taxation. The tax rules are being revisited to address the challenges (nexus, characterisation, etc.) posed by increasing digitalisation. We have been witnessing a spate of unilateral measures being implemented by jurisdictions the world over.

While the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework has been working to achieve a consensus on redesigning the existing tax system to meet the challenges of digitalisation of business (Pillar One and Pillar Two proposals), the United Nations (UN), through its Committee of Experts on International Cooperation in Tax Matters, has released the finalised draft of a new Article 12B, to include income from automated digital services (ADS) in the 2021 version of the UN Model Tax Convention.

In order to decipher the contours of the new article for you and discuss its implications for businesses and international tax rules, we are pleased to present a podcast featuring Mr. Rajat Bansal, one of the key architects of the article, and Mr. Akhilesh Ranjan, former member of CBDT. The discussion would be moderated by Mr. Pavan Kakade, a subject matter expert.

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