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WU Vienna Tax law


Michael Lennard

Michael joined the United Nations in New York in November 2006, as Chief, International Tax Cooperation and Trade in the Financing for Development Office (FfDO). This work has a particular focus on ensuring the fairness and workability of international tax norms, including achieving greater developing country input into those norms, and encouraging cooperation to improve tax systems and administrations for the benefit of all stakeholders, as a spur to sustained development. Previously Michael worked in the OECD Tax Secretariat in Paris and prior to that at the Australian Tax Office. Michael has published widely and has spoken on tax matters at universities such as Harvard, Leiden, New York University, Oxford, Sydney, Uppsala, and Vienna, and at the UN, IMF, World Bank and OECD.

The United Nations Model Double Taxation Convention between Developed and Developing Countries is widely used in the negotiation and administration of tax treaties by developing (and some developed) countries among the United Nations’ 193 nation membership. The Model’s differences from the OECD Model Convention are something that all those dealing with developing countries, or coming from such countries, should be aware of. The general reservation in the UN Model of more taxing rights to the country where economic activity occurs and less to the country of residence of the company earning returns from those activities is particularly relevant in current debates about where value is created and how the profits it creates should be taxed. This lecture will also outline current work related to the UN Model in the areas of transfer pricing, taxation of the extractive industries, and the taxation of technical services, including the new fees for technical services article due for incorporation in the 2016 update of the Model. The policy and administration issues addressed in such an article will be examined as to their immediate and broader significance.

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