UN MTC Article 8 was the source rule surrender on Article 8 a blunder? The case study of Pakistan Muhammad Ashfaq Ahmed
By: Ahmed, Muhammad Ashfaq
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Material type: 
ArticlePublisher: 2020Subject(s): TRANSPORTES MARITIMOS | TRAFICO MARITIMO | COMERCIO INTERNACIONAL | IMPUESTOS | DOBLE IMPOSICION | PAISES EN DESARROLLO | CONVENIOS | NACIONES UNIDAS
In:
Intertax v. 48, Issue 1, January 2020, p. 103-118Summary: The United Nations Model Tax Convention (UN MTC) Article 8 allocates taxing rights on international traffic to the state of effective management. Article 8 (Alternative B), however, to the extent of shipping, conditionally allows some taxing rights to source state, too. The study posits that by surrendering source rule on Article 8, UN MTC ditched developing countries. This allowed airlines and shiplines stationed in developed countries not only generate large sums of revenues by hitting developing countries' ports but also repatriate them tax free to a sustained disadvantage to the developing countries.
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| OP 2141/2020/1-4 The troubled story of the Hungarian advertisement tax | OP 2141/2020/1-5 Advance pricing arrangements | OP 2141/2020/1-6 Challenges of applying the comparability analysis in curtailing transfer pricing | OP 2141/2020/1-7 UN MTC Article 8 | OP 2141/2020/3 Intertax | OP 2141/2020/3-1 Lost in construction | OP 2141/2020/3-2 Double taxation resulting from the ATAD |
Resumen.
The United Nations Model Tax Convention (UN MTC) Article 8 allocates taxing rights on international traffic to the state of effective management. Article 8 (Alternative B), however, to the extent of shipping, conditionally allows some taxing rights to source state, too. The study posits that by surrendering source rule on Article 8, UN MTC ditched developing countries. This allowed airlines and shiplines stationed in developed countries not only generate large sums of revenues by hitting developing countries' ports but also repatriate them tax free to a sustained disadvantage to the developing countries.
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