At its 29th and 30th sessions, the UN Committee approved the introduction of Article 12C UN Model, including both its wording and the accompanying Commentary. Only its formal publication in the next update of the UN Model remains pending. Substantively, this new distributive rule expands the allocation of taxing rights in favour of the source state. At the same time, Article 12C UN Model marks a systemic shift from an approach based on net amounts to the taxation of gross insurance premiums. Nadine Chiba provides a first overview of the relevant amendments to be incorporated into the next update of the UN Model and the corresponding Commentary.
