Article 12 of the Global Tax Treaty Commentaries (GTTC) has now been extended with the addition of Article 12A: Technical Services (UN Model (2017)) by Adolfo Martín Jiménez.
Article 12A of the UN Model is a new provision on the taxation of technical services at source. The rule allows states to tax the provision of these services even if the provider does not have a physical connection with the source state and the services are provided abroad.
The GTTC is the authoritative source for analysis of and commentary on tax treaty practices across the globe. Authored by leading international tax experts, it sets out chapters for each of the OECD Model articles.