Business Groups Remain Critical of UN Model Treaty Change

June 23, 2025, 10:13 PM UTC

A new article on taxation of services, adopted earlier this year as part of the United Nations model tax treaty, is broad and shifts away from how companies are normally taxed, an international business group said Monday.

The International Chamber of Commerce is concerned about the scope of Article 12AA, a provision that would expand the rights of countries to tax cross-border services.

“There is a fundamental shift in this article from the permanent establishment rules and also the definition of services indicated in this article. So it really goes into any type of services,” said Luisa Scarcella, global ...

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