Plain meaning
A model tax treaty used as a reference in tax-treaty negotiations, often with more source-country emphasis than the OECD model.
Also called
UN Model Double Taxation Convention
United Nations Model Tax Convention
Key points
- The UN model is not itself a Canadian treaty but can influence treaty negotiations and interpretation.
- It often gives more attention to source-country taxing rights than the OECD model.
- Actual treaty text may differ from both the UN and OECD models.
- The model is useful context for understanding why treaty provisions vary across countries.
Why it comes up
The UN model can matter in treaty policy involving developing countries, withholding taxes, permanent establishments, and source-country taxation.