"Article 14 of the UN Model Convention gives exclusive rights to the source country to tax Independent Services." Examine the correctness of the…
CA Final · Direct Tax Laws and International Taxation · PYQS · January 2026
"Article 14 of the UN Model Convention gives exclusive rights to the source country to tax Independent Services." Examine the correctness of the above statement.
Suggested Answer and Working Notes:
The statement is not correct. Article 14 of the UN Model Convention does not give exclusive rights to the source country to tax Independent Services. It gives an exclusive right to the residence country to tax Independent Services except in the following two circumstances when such Independent Services may also be taxed in the source country: (i) If he has a fixed base regularly available to him in the source country for the purpose of performing his activities. (ii) If his stay in the source country is for a period or periods amounting to or exceeding in the aggregate 183 days in any 12 months period commencing or ending in the fiscal year concerned.
Topics: Overview of Model Tax Conventions
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