The tenth session of the Committee of Experts on International Cooperation in Tax Matters will address issues related to the next update of the UN Model Double Taxation Convention between Developed and Developing Countries, including various issues related to the application of treaty rules to hybrid entities (Article 4), the concept of “permanent establishment,” the meaning of “connected projects” and physical presence issues (Article 5), the meaning of “auxiliary activities” under Article 8 (Transportation), the Commentary to Article 9 (Associated Enterprises), Article 12 on Royalties, Exchange of Information (Article 26), and methods for elimination: conflicts of qualification, and conflicts of interpretation (Article 23). The Committee will also discuss cross-cutting issues under the UN Model, such as taxation of services. Other issues on the agenda of the session include work towards the next update of the UN Practical Manual on Transfer Pricing for Developing Countries, the draft Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries, taxation of extractive industries, Base Erosion and Profit-Shifting (BEPS) and its consequences for developing countries, cooperative compliance and corporate governance in tax matters, as well as capacity development.  

dates: 27-31 October 2014  
venue: UN Office in Geneva  
location: Geneva, Geneve, Switzerland  
contact: Michael Lennard  
phone: 1 (917) 367-5734  
e-mail: lennard@un.org  
www: http://www.un.org/esa/ffd/tax/tenthsession/index.htm