Special Features of the UN Model Convention

S. VIIEditors’ Preface

This volume is a compilation of the master’s theses of the full-time students attending the 2018–19 class of the postgraduate LL.M. program “International Tax Law” at WU (Vienna University of Economics and Business). The general topic for the classes of these master’s theses was “Special Features of the UN Model Convention” with each thesis focusing on a different aspect of the UN Model Convention.

The UN Model Convention is an important tool in international tax policy and often serves as starting point for treaty negotiations involving emerging and developing countries. While the UN Model Convention largely follows the OECD Model Convention in terms of structure and content, its distinctive trait is a clear focus on the interests of emerging and developing countries. This aim is reflected in many of the UN Model Convention’s provisions and is the reason for most of the differences between the UN and the OECD Model Convention.

This volume focusses on the special features of the UN Model Convention that distinguish it from the OECD Model Convention and provides a comprehensive analysis of these features and their relevance in international tax policy. The book is divi...