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The U.N. Digital Tax Article 12B

Level: Intermediate
Runtime: 65 minutes
Recorded Date: August 25, 2021
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  • The UN Tax Committee?
  • UN Capacity Building?
  • Next steps for global tax norm-setting?
  • Q&A
Runtime: 1 hour, 5 minutes
Recorded: August 25, 2021

Difficulty: Experienced Attorneys (Non-Transitional)


The UN Tax Committee approved insertion of article 12B and its Commentary into the 2021 United Nations Model Tax Convention. Unlike in the OECD-led work on Pillar One, the taxing right is not conditioned on revenue thresholds and only applies to companies engaged in the digital economy, so-called automated digital service companies. The new taxing right would apply to income from automated services such as the supply of user data, platform services, online search engines, and cloud computing services. The model treaty provisions allow source countries to apply a withholding tax on gross payments or companies can elect for the withheld amount to be based on profits earned in the source country. Mr. Lennard, who serves as Secretary of the UN Tax Committee, will give insights into the process that led to the UN Model changes and their implications in light of Pillar One.

This program was recorded on August 25th, 2021.

Provided By

American Bar Association
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Michael Lennard

Chief of International Tax Cooperation and Trade in Financing for Development Office
United Nations

Michael Lennard is Chief of International Tax Cooperation and Trade in the Financing for Development Office (FfDO) of the United Nations. This work has a particular focus on ensuring the fairness and workability of international tax norms, including achieving greater developing country input into those norms, and encouraging cooperation to improve tax systems and administrations, as a spur to sustained development.

Previously Mr Lennard was a tax treaty adviser in the OECD Tax Treaty Secretariat in Paris for three years and prior to that he worked on tax treaty and other international tax matters at the Australian Tax Office. He had earlier worked in the Australian government’s Office of International Law.

He has led Australian negotiating teams on trade, investment, environmental and tax treaty matters and has prepared argument for matters before the Australian High Court, the US Supreme Court and the WTO. His published work on treaty interpretation has been cited before WTO panels and before the WTO Appellate Body. Mr Lennard has degrees from the University of Tasmania, the Australian National University and Cambridge.

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