Citation:
In: Tax notes international. - Falls Church. - Vol. 91 (2018), no. 4 ; p. 367-372
Description:
In this article, the author examines the newly
introduced article 12A of the U.N. model tax
treaty, which specifically addresses fees for
technical services, discussing how the article
functions within the model, how it responds to
concerns about base erosion and profit shifting,
and how it fits into today’s international tax
environment.
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