TY - ADVS
T1 - Tax Treaty Talks S1E3: Royalties with Professor Luis Eduardo Schoueri
AU - Baptiste Gonzalez, Maria Paula
AU - Poubel, Lucas
AU - Schoueri, Luis Eduardo
PY - 2025/5/5
Y1 - 2025/5/5
N2 - In this episode, we sit down with Professor Luís Eduardo Schoueri to discuss Article 12 of model tax conventions, which addresses the taxation of royalties. We explore the policy tensions behind source and residence taxation, differences between the OECD and UN approaches, and the evolving role of Article 12 in treaty practice. From software payments to technical services, this conversation unpacks one of the most debated provisions in international tax law.
AB - In this episode, we sit down with Professor Luís Eduardo Schoueri to discuss Article 12 of model tax conventions, which addresses the taxation of royalties. We explore the policy tensions behind source and residence taxation, differences between the OECD and UN approaches, and the evolving role of Article 12 in treaty practice. From software payments to technical services, this conversation unpacks one of the most debated provisions in international tax law.
M3 - Digital or Visual Products
ER -
