UN Publishes Possible Changes to Articles and Commentaries of the UN Model including New Limitation on Benefits Article

The UN has published an agenda item on possible changes to Articles and Commentaries of the UN Model Treaty to be discussed during the Thirteenth Session of the Committee of Experts on International Cooperation in Tax Matters, which will be held 5 to 8 December 2016. The possible changes are meant to address BEPS issues and include:

• A new Article 22 (Limitation on Benefits);
• The addition of new definitions of the terms "Pension Fund" and "Special Tax Regime" in Article 3 (General Definitions…