Critically evaluate the plans for the introduction into the United Nations Model Tax Convention of a new article permitting withholding tax to be charged on payments to non-residents in respect of fees for technical services.

Essay Plan:

1. Brief introduction (Background of United Nations Model, what is withholding tax, technical services)

2. Feature Material

—Wording of new article (The topic is Technical service fee)

—What and why countries use UN model

—Position regards OCED model (differences between UN model and OCED model)

3. Critical analysis

—Why do group of countries want this article?

—What effects will it has?

—Will treaty partner country agree and insert it into treaties? (Select TWO countries by your own, like UK and India)

—Will it works? (Need your own opinion)

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