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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Bibliographic Details
Main Author: Ziemowit Kukulski
Format: Article
Language:Polish
Published: Lodz University Press 2025-07-01
Series:Acta Universitatis Lodziensis Folia Iuridica
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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 Rules governing taxation of income from cross-border services adopted by the UN Model in pre-digital era are outdated.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.
ISSN:0208-6069
2450-2782