Aufsuchung und Ausbeutung natürlicher Ressourcen im UN-Musterabkommen 2025

In the next few months, the 2025 version of the UN Model Double Taxation Convention Between Developed and Developing Countries will be rolled out and will substantially differ from the version dating 2021. It will include many changes discussed and decided by the UN Committee of Experts on International Cooperation in Tax Matters in the past four years. These changes include among other things a new stand-alone Article 5A to be introduced into the Convention on “Income from the Exploration for, or Exploitation of Natural Resources” along with a comprehensive commentary. The new article gives rise to a deemed permanent establishment and allows source states to tax the attributable profits, if activities connected therewith are carried out for at least 30 days in any twelve-month period commencing or ending in the fiscal year concerned. The author takes an initial look at the new provision that will be introduced into the UN Model Double Taxation Convention 2025 that soon will be released.