: Generally pushes for lower withholding tax rates (typically 5–15%) to encourage investment.
: Often prevents separate taxation of technical service fees unless linked to a PE. The Impact of the OECD and UN Model Conventions...
: Includes specific provisions for withholding taxes on management, consultancy, and technical fees . 2. Evolution and 2025-2026 Modernization : Generally pushes for lower withholding tax rates
: Requires a stricter "fixed place of business" and a 12-month threshold for construction sites. Business Profits & Technical Fees :
The most significant impact of these models is how they allocate the right to tax specific types of income between countries: :
As digital economies evolve, both models are undergoing major shifts to address "tax-less" digital profits and remote work:
: Allows for higher withholding rates , ensuring the country where the income is generated retains more revenue. Business Profits & Technical Fees :