Special Event by IFA Sektion SĂŒdwest
On 17 June 2026, the IFA Sektion SĂŒdwest held a special event entitled âMore Source State â Less OECD? â The UN Model Tax Convention and the UN Framework Convention on Taxation â Implications for Cross-Border Taxation, Permanent Establishments and Transfer Pricing â The Case of Indiaâ at Ulm University.
The first part focused on the major developments and shifts between the OECD and the UN, specifically as they relate to Articles 12, 12A and 12B of the UN Model Tax Convention, with two excellent presentations by Professor Dr Ekkehart Reimer and Dr Dhruv Janssen-Sanghavi. Björn Hannemann, Head of International Tax at Carl Zeiss AG, provided a brilliant practical introduction using a helpful diagram and current examples drawn from Carl Zeiss AGâs operations in India. This was perfectly complemented by presentations from Prashant Kapoor, Partner at KPMG in India, and Praveen Ranka, Partner at BSR & Co. LLP in India, who covered both recent case law and practical transfer pricing issues, as well as the interface with customs duties.
Further information on the event can be found here.