Tax consequences of the digitalized economy
– issues of relevance for developing countries

Summary
This note reflects the progress made in the Subcommittee on Tax Issues related to the Digitalization of the Economy.

It presents a draft for a proposed introduction of a new Article 12B (“Income from Automated Digital Services”) into the UN Model with Commentary, prepared by a Drafting Group consisting of 14 members of the Committee seeking consideration of an additional
provision in the UN Model Tax Convention to deal with certain aspects of taxation in an increasingly digitalized economy.

It also contains a short summary by the Co-Coordinators of the written and oral comments submitted by other members in preparation for, during and after a virtual meeting of the
Subcommittee held on 25, 26 and 27 September. The Drafting Group has taken these comments into consideration as far as they thought they contributed to the improvement of the proposed article.

At its 21st meeting, the Committee is invited to have a discussion on the amended Draft for Article 12B included in Annex 1 to this note and on the submitted comments summarized in this note and to take such decisions as it sees fit on how best to take the
matter forward including on the proposed text.

Download Full Report October 2020