Special event organised by the IFA South-West Section

On 17 June 2026, a special event organised by the IFA’s South-West Section, entitled ‘More Source State – Less OECD? – The UN Model Tax Convention and the UN Framework Convention on Taxation – Implications for Cross-Border Taxation, Permanent Establishments and Transfer Pricing – The Case of India’ took place at the 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 transition with a diagram and current examples drawn from Carl Zeiss AG’s operations in India. This was perfectly complemented by presentations from Prashant Kapoor, Partner at KPMG India, and Praveen Ranka, Partner at BSR & Co. LLP India, who covered both recent case law and practical transfer pricing issues, and even the interface with customs duties.