000			02104nab a2200217 c 4500
999			_c149590 _d149590
003			ES-MaIEF
005			20240605184028.0
007			ta
008			240605t2023 ne |||||o|||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_966603 _aAhmed, Muhammad Ashfaq
245		0	_aUN MTC Article 14 _helectrónico _bthe mistaken retention _c Muhammad Ashfaq Ahmed
500			_aResumen.
520			_aThe OECD deleted Article 14 from its Model Tax Convention (MTC) in 2000, however, the UN decided to retain it in 2009. The OECD has since been chastized for eliminating it and the UN eulogized for retaining it. This article, contrary to the prevailing perspective, supports the ‘delete decision’, though for reasons diametrically different from those on which Organization for Economic Cooperation and Development (OECD) based its decision in 2000. It berates the UN for the ‘retain decision’ by debunking the grounds thereof and by mounting new arguments. In fact, it turns the mainstream scholarships’ professed position upside down that Article 14s continued presence on UN MTC accrued developing countries substantial economic benefits and broadened their tax base. It is argued that the deletion of UN MTC Article 14(1)(c) in 1999 through an angularly established setup – the Focus Group – was dramatic, mysterious, and undefendable warranting fresh and deeper scrutiny. This article postulates that without a robust built-in anti-base erosion principle, which was deleted in 1999, Article 14s presence in the UN MTC is counterproductive, base eroding, and inimical to fiscal interests of developing countries. Therefore, it strongly proposes to either restore the deleted Subparagraph 1(c) or also delete the retained rump Article 14 itself – sooner than later.
650		4	_aACTIVIDADES PROFESIONALES _94544
650		4	_aIMPUESTOS _947460
650		4	_aMODELO DE CONVENIO DE NACIONES UNIDAS _969624
650		4	_aMODELO DE CONVENIO OCDE _967760
773	0		_9171820 _oOP 2141/2023/10 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 51, issue 10, October 2023, 17 p.
942			_cRE