Special Features of the UN Model Convention

1. S. 4Introduction

Global tax governance is currently the trending discussion in the international tax policy regime as the existing international tax rules are criticized for being archaic and not suited for the modern digital economy. In this context, it is worth reminiscing the concluding remarks from the Organization for Economic Co-Operation and Development (OECD) tax policy director on a panel discussion in 2018 that “Consensus is better than Chaos”. The plea by the OECD tax policy director to arrive at a multilateral consensus on tax policies by all governing stakeholders is mostly due to the chaos created by a multinational enterprise which has evaded taxes amounting to almost US 600 million dollars. Due to the mounting tax evasions, international tax policy is under an immense spotlight and has become a critical agenda point on all significant political discourses in recent times. Even though the current tumultuous scenario in the international tax regime, is attributable to the evolution of the digital economy, was the tipping point was the 2008 global financial crisis which acted as a significant catalyst for necessary policy reforms and provided the much-needed impetus to b...