A misconceived change U.N. includes software in the scope of royalty by Najeeb Memon
By: Memon, Najeeb
.
Material type: 
ArticlePublisher: 2024Subject(s): COMERCIO ELECTRONICO | IMPUESTOS | TRATADOS INTERNACIONALES | NACIONES UNIDAS
In:
Tax Notes International v. 115, n. 7, August 12 2024, p. 995-1007Summary: Najeeb Memon is a member of the Federal Board of Revenue, Government of Pakistan. The views expressed in this article are those of the author and do not necessarily reflect the views of the government of Pakistan or any other organization. In this article, Memon discusses the legal nature of software and argues that the U.N.’s recent addition of software to article 12 of its model treaty was misguided.
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| OP 138-Bis/2024/115/6-4 Limitation on benefits or principal purpose test? | OP 138-Bis/2024/115/6-5 The UTPR | OP 138-Bis/2024/115/7 Tax Notes International | OP 138-Bis/2024/115/7-1 A misconceived change | OP 138-Bis/2024/115/7-2 The history and effect of residence-based taxation | OP 138-Bis/2024/115/7-3 Taxation of foreign income earned by individuals and minority shareholders of passive foreign corporations | OP 138-Bis/2024/115/8 Tax Notes International |
Najeeb Memon is a member of the Federal Board of Revenue, Government of Pakistan. The views expressed in this article are those of the author and do not necessarily reflect the views of the government of Pakistan or any other organization. In this article, Memon discusses the legal nature of software and argues that the U.N.’s recent addition of software to article 12 of its model treaty was misguided.
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