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Tax Sovereignty Principle and Its Peaceful Coexistence with Article 12B of the UN MTC

South Centre, Geneva has recently published my above titled article as a Tax Cooperation Policy Brief.


The write-up analyses the important features of Article 12B which essentially mandates source taxation of income from automated digital services (ADS). The conclusion derived from the analysis is that simplicity and administrability is the essence of Article 12B. Article 12B neither takes away any taxing right enshrined in the existing provisions of the UN MTC nor does it fetter the tax sovereignty of States in terms of applying curbs on their domestic laws. Article 12B merges seamlessly with the existing provisions of the UN MTC and keeping in mind the motto of the UN which is ‘peaceful coexistence’, Article 12B is completely aligned and coexistent with the Tax Sovereignty Principle.


The article may be viewed at the below mentioned link:

https://www.southcentre.int/wp-content/uploads/2021/06/Tax-PB-14.pdf



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