IBA Annual Conference Paris 2023

29 Oct - 3 Nov 2023

Room 351, Level 3

Session information

How do the OECD and the UN address international tax issues (past, present and future)?
Room 351, Level 3

Committee(s)

Taxes Committee (Lead)

Description

The OECD and the UN have been addressing international tax issues differently to avoid or minimise double taxation. Initially, they had a different approach to tax passive income and technical services, as well as on the permanent establishment threshold. With the BEPS project after the 2008 financial crisis and the more recent Two-Pillar solution, the OECD has initially taken the lead to set new international tax rules - in the context of the inclusive framework of 140 countries - to avoid double taxation and to provide a new standard of fair taxation. In that context, a new international tax term arose: “market jurisdiction”. The UN is, however, still on the scene with its Model Convention’s Article 12B, with a renewed interest in contributing to and - why not - sharing the lead of the discussion. The panel will focus on where the two most important global tax policy drivers (i.e., the OECD and the UN) currently stand on the more relevant international tax issues, what their course of action seems to be driven by, whether it should be adjusted in some ways, and what to expect for the future.

Session / Workshop Chair(s)

Margriet Lukkien Loyens & Loeff, Amsterdam, Netherlands
Leandro M Passarella Passarella Abogados, Buenos Aires, Argentina

Speakers

David Bradbury OECD, Paris, France
Charanya Lakshmikumaran Lakshmikumaran & Sridharan, New Delhi, Delhi, India
Michael Lennard United Nations, New York, New York, USA
Loren Ponds Miller & Chevalier Chartered, Washington, District of Columbia, USA