Some Policy Reflections on the Envisaged New Article 12AA (Fees for Services) of the Upcoming Update to the UN Model

This article examines the envisaged article 12AA of the UN Model on fees for services, assessing its scope, source-taxing implications and relationship with existing treaty provisions. It argues that, despite aiming for conceptual clarity, article 12AA may deepen uncertainty unless coordinated with broader UN reforms on cross-border services.