On August 6th, 2020, the UN Committee of Experts on International Cooperation in Tax Matters released a proposed, optional tax treaty provision on digital service payments. The new Article 12B set to be included in the UN Model Double Taxation Convention between Developed and Developing Countries is captioned “Income from Automated Digital Services" and is followed by a detailed commentary. The draft provision and its commentary have been prepared in accordance with the outcomes of the 20th session of the committee concerning the drafting of a provision that would allow the source taxation of income from the rendering of automated digital services. Stefan Bendlinger and Matthias Mitterlehner provide a first analysis of this new approach.
