Attention:
Card image cap

The U.N. Digital Tax Article 12B


Level: Intermediate
Runtime: 65 minutes
Recorded Date: August 25, 2021
Click here to share this program
Download PDF
Closed Caption

Agenda

  • The UN Tax Committee?
  • UN Capacity Building?
  • Next steps for global tax norm-setting?
  • Q&A
Runtime: 1 hour, 5 minutes
Recorded: August 25, 2021

Difficulty: Experienced Attorneys (Non-Transitional)

Description

The UN Tax Committee approved insertion of article 12B and its Commentary into the 2021 United Nations Model Tax Convention. Unlike in the OECD-led work on Pillar One, the taxing right is not conditioned on revenue thresholds and only applies to companies engaged in the digital economy, so-called automated digital service companies. The new taxing right would apply to income from automated services such as the supply of user data, platform services, online search engines, and cloud computing services. The model treaty provisions allow source countries to apply a withholding tax on gross payments or companies can elect for the withheld amount to be based on profits earned in the source country. Mr. Lennard, who serves as Secretary of the UN Tax Committee, will give insights into the process that led to the UN Model changes and their implications in light of Pillar One.

This program was recorded on August 25th, 2021.

Provided By

American Bar Association
Card image cap

Panelists

Card image cap

Michael Lennard

Chief of International Tax Cooperation and Trade in Financing for Development Office
United Nations

Michael Lennard is Chief of International Tax Cooperation and Trade in the Financing for Development Office (FfDO) of the United Nations. This work has a particular focus on ensuring the fairness and workability of international tax norms, including achieving greater developing country input into those norms, and encouraging cooperation to improve tax systems and administrations, as a spur to sustained development.

Previously Mr Lennard was a tax treaty adviser in the OECD Tax Treaty Secretariat in Paris for three years and prior to that he worked on tax treaty and other international tax matters at the Australian Tax Office. He had earlier worked in the Australian government’s Office of International Law.

He has led Australian negotiating teams on trade, investment, environmental and tax treaty matters and has prepared argument for matters before the Australian High Court, the US Supreme Court and the WTO. His published work on treaty interpretation has been cited before WTO panels and before the WTO Appellate Body. Mr Lennard has degrees from the University of Tasmania, the Australian National University and Cambridge.


Card image cap

Similar Courses

Card image cap
122 minutes
A New Regime of Transparency: Anti-Money Laundering and Corporate Transparency Acts of 2020 and Expansion of Cryptocurrency Reporting
Join us for a two-hour program covering the substantial legislative changes made by the Anti-Money Laundering and Corporate Transparency Acts of 2020 and the recent expansion of cryptocurrency reporting announced by FinCEN.

American Bar Association

$165

Add to Cart
Card image cap
89 minutes
Average Income Test in LIHTC Projects: Recent IRS Regulations, Updates & Implications
On October 30, 2020, the IRS published in the Federal Register proposed regulations on the LIHTC Average Income Test (AIT) minimum set-aside for public comment. The regulations, which are not yet finalized, would provide guidance on implementation of the AIT.

American Bar Association

$115

Add to Cart
Card image cap
93 minutes
Biden's Tax Plan: The Good, the Bad and the Unknown
This seminar will provide a broad overview of the core proposals of President Biden’s tax plan and the likelihood and timeline for their implementation.

American Bar Association

$115

Add to Cart
Card image cap
64 minutes
Building a Privacy Roadmap: GC’s Role in Strategy Implementation
It has become increasingly important to create a foolproof privacy roadmap for your organization. Privacy compliance may be the largest challenges that GCs have to face, so it’s essential to put programs into place and create a culture of collaboration where the whole organization is aligned on privacy policies. With the fear of litigation increasing, GCs need to be prepared to respond and have a plan of attack.

General Counsel Conference

$65

Add to Cart
Previous Next