A note from the UN Committee of Experts on International Cooperation in Tax Matters has been published regarding changes to the Commentary on Article 12 (Royalties) of the UN Model Tax Convention in relation to the new Article 12B (Income from Automated Digital Services) and the inclusion of computer software payments in the definition of royalties. While the new Article 12B was approved as previously reported, the inclusion of computer software payments in the definition of royalties was no…