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Special Features of the UN Model Convention
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amendi...
The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention
Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and othe...
Destination Net Zero
The need to decarbonize international aviation and maritime has long been overlooked. The two sectors account for a small but rapidly growing share of global CO2 emissions, and could rise to as much as 15 to 40 percent by 2040. Pricing these emissions could help global climate policy in two ways. First, it could accelerate technological development while incentivizing efficiency, kick-starting the sectors’ transition to net zero while addressing the sectors’ hitherto favorable tax treatment. Second, pricing could raise up to $200 billion a year in revenues by 2035, which could be allocated to climate finance or other uses. There are significant political obstacles, however, notably reaching consensus on revenue allocation and managing price impacts, which are substantive for flight tickets but less so for shipped goods. Pricing variants, like ‘fee and rebate’ schemes (feebates), have lower price impacts but raise fewer revenues. This paper discusses these policies, using a new model to quantify impacts on fuel use, emissions, revenues, production and economic costs, and on vulnerable states..
Energy and the Environment
This book shows the complexity of the energy-environment nexus under international economic law, existing gaps and further actions for improvement.
International Trade and Sustainability
This book examines how international trade can be utilised to build a sustainable future. It highlights how international trade and climate regimes can work together to put in place a Green New Deal. The potential of mega-regional trade agreements to aid climate change mitigation and power the energy transition is explored in relation to the energy section, with a particular focus on clean technology. Broader perspectives are provided by an analysis of international trading systems in the Caribbean and Pacific Islands and a review of climate change law and policy in Brazil, Russia, India, and China. This book aims to provide an interdisciplinary understanding of how green trade can be achieved. It will be relevant to researchers and policymakers interested in international trade and environmental economics.
Taxation in a Global Digital Economy
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
African Financial Ecosystem
Historically and contextually, various integration models were experimented with by colonial powers, but these systems largely collapsed post-independence. For instance, the French attempted to maintain cohesion but prioritized their own interests, leading to fragmentation. Efforts in East and West Africa similarly faltered, as each nation pursued its own agenda without a unified political will. South Africa made a notable attempt, but integration never materialized; it would have required a different approach, such as the adoption of a SADC currency. The recent endeavors of AES countries and Zimbabwe’s new currency inject fresh dynamics into this ecosystem. Concurrently, the rise of new t...
International Tax at the Crossroads
In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.
Tax Cooperation in an Unjust World
A demonstration of the role that tax systems play in achieving international justice; this book establishes that current international tax systems facilitate wealthy states claiming an unfair share of the global economy, shows how this system feeds off human suffering, and explains how to achieve justice using existing international structures.
