United Nations Model Tax Convention – Proposed Inclusion of Software in the Definition of Royalties in Article 12: Comments on the 2020 Discussion Draft
{"title":"United Nations Model Tax Convention – Proposed Inclusion of Software in the Definition of Royalties in Article 12: Comments on the 2020 Discussion Draft","authors":"Ganesh Rajgopalan","doi":"10.2139/ssrn.3715609","DOIUrl":null,"url":null,"abstract":"United Nations has issued a Discussion Draft of the proposed changes to Article 12 relating to Royalties contained in the UN Model on Double Tax Conventions. The proposal intends to add payments for use of computer software in the definition of Royalties in that Article. The article first examines the history and the root cause behind the controversy and suggest changes to the UN Commentary by departing from the wordings of the OECD Commentary on the same Article. The article then comments on the arguments for and against the proposed change contained in the Discussion Draft for their validity and their practicality.","PeriodicalId":406666,"journal":{"name":"Applied Computing eJournal","volume":"39 1","pages":"0"},"PeriodicalIF":0.0000,"publicationDate":"2020-09-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"Applied Computing eJournal","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.2139/ssrn.3715609","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"","JCRName":"","Score":null,"Total":0}
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Abstract
United Nations has issued a Discussion Draft of the proposed changes to Article 12 relating to Royalties contained in the UN Model on Double Tax Conventions. The proposal intends to add payments for use of computer software in the definition of Royalties in that Article. The article first examines the history and the root cause behind the controversy and suggest changes to the UN Commentary by departing from the wordings of the OECD Commentary on the same Article. The article then comments on the arguments for and against the proposed change contained in the Discussion Draft for their validity and their practicality.
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