Article 12B of the UN Model is presented as an alternative for developing countries to the OECD’s Pillar One global proposal. It would be a simpler option in its implementation, operating through a system of withholding taxes, which could generate fewer disputes arising from its interpretation. This proposal could also mean higher revenues for source states than what is offered by Pillar One by attributing a significant portion of revenues to the jurisdiction of the payer. Article 12B could also provide an option to avoid the double taxation of unilateral measures, should they continue over time. However, article 12B of the UN Model also presents some elements that need attention, such as (i) the fact that it constitutes a ring-fencing proposal; (ii) the uncertain definition of the concept of “payer”; (iii) the involvement of financial institutions as withholding agents; (iv) the possible distribution of income among a smaller number of jurisdictions as a consequence of the connection factor selected; and (v) the use of gross income as the basis for calculation. This determines that article 12B has clear strengths and weaknesses in comparison with the other proposals for the taxation of the digital economy that are analysed throughout the article (i.e. Pillar One and digital services tax).