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of <h1>Article 12B of UN Tax Convention: Taxing Automated Digital Services Income Between States with Negotiable Tax Rates, Exceptions Included.</h1> Article 12B of the UN Model Tax Convention addresses taxation of income from automated digital services between Contracting States. It allows a State to tax such income if payments are made to a resident of another State, with the tax rate subject to bilateral negotiation. Exceptions apply if the beneficial owner operates through a permanent establishment or performs independent services in the State where the income arises. The article defines 'automated digital services' and outlines conditions under which income is deemed to arise in a State. It also addresses taxation of excess payments in cases of special relationships between parties.
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