The 2021 version of the United Nations Model Tax Convention was recently released ahead of the 24th Session of the Committee of Experts on International Cooperation in Tax Matters, which is being held from 4 to 7 April and 11 to 12 April 2022. This is the fifth edition of the Model Convention. The most important changes included in the 2021 version of the UN Model address concerns expressed by developing countries regarding tax treaty obstacles to the taxation of foreign enterprises on inco…