Ziemowit Kukulski
Abstract
Digitalization challenges international tax law provisions dealing with eliminating double taxation of income from cross-border services. In the paper the following issues are discussed: rules elimination double taxation of income from cross-border services in the pre-digital era from the UN Model perspective as well as the UN Model’s response to challenges related to eliminating double taxation of income from cross-border services in the digital era as well as its possible impact on countries’ tax treaty practice. Rules governing taxation of income from cross-border services adopted by the UN Model in pre-digital era are outdated. This raises a question whether recently adopted provisions dealing with fees for technical services and automated digital services change the reality in that area.
Citation format
KUKULSKI, Ziemowit. Eliminating double taxation of income from cross-border services in the digital era from the UN model perspective. Acta Universitatis Lodziensis. Folia Iuridica, 2025.