Proposal for Subject-to-Tax-Rule in UN Model Convention
The UN has published a draft proposal for the inclusion of a subject-to-tax rule in the UN Model Convention that was discussed during the 25th Session of the Committee of Experts on International Cooperation in Tax Matters, which was held from 18 to 21 October 2022. The proposed rule regarding taxation by the source state is as follows:
(a) This Convention shall not affect the taxation by a …
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