On 28 August 2026, the UN Tax Committee released the 2025 UN Model Tax Convention, incorporating changes agreed in recent years, including a subject-to-tax rule.
Key additions include new articles on natural resources (article 5A), fees for services (article 12AA) and insurance premiums (article 12C), plus expanded royalties covering software.
The update also revises article 8 on international transport and article 25 on MAP, and drops “between Developed and Developing Countries” from its title.