Eliminating Double Taxation of Income from Cross-Border Services in the Digital Era from the UN Model Perspective
Digitalization challenges international tax law provisions dealing with eliminating double taxation of income from cross-border services. In the paper the following issues are discussed: rules elimination double taxation of income from cross-border services in the pre-digital era from the UN Model...
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| Format: | Article |
| Language: | Polish |
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Lodz University Press
2025-07-01
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| Series: | Acta Universitatis Lodziensis Folia Iuridica |
| Subjects: | |
| Online Access: | https://czasopisma.uni.lodz.pl/Iuridica/article/view/24818 |
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| Summary: | Digitalization challenges international tax law provisions dealing with eliminating double taxation of income from cross-border services. In the paper the following issues are discussed: rules elimination double taxation of income from cross-border services in the pre-digital era from the UN Model perspective as well as the UN Model’s response to challenges related to eliminating double taxation of income from cross-border services in the digital era as well as its possible impact on countries’ tax treaty practice. Rules governing taxation of income from cross-border services adopted by the UN Model in pre-digital era are outdated. This raises a question whether recently adopted provisions dealing with fees for technical services and automated digital services change the reality in that area.
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| ISSN: | 0208-6069 2450-2782 |