Navigating the Future of International Taxation: Dryllerakis Law Firm at the 6th Law Forum on Taxation

On 23 September, the Divani Caravel Hotel welcomed the 6th Law Forum on Taxation, an event organized by CLEON Conferences & Communications and held under the auspices of SEV Hellenic Federation of Enterprises, ENEISET and the Economic Chamber of Greece. As a Silver Sponsor, Dryllerakis Law Firm reinforced its commitment to shaping the dialogue on contemporary tax policy in Greece and beyond.

Representing our Firm, Tax Partner Dimitrios Karavas and Associate Athina Bestitzanou took the stage for a compelling panel discussion titled: “OECD and UN Model Tax Conventions: Towards a Bipolar International Tax System?”

During the session, our team unpacked the mechanics of Double Taxation Conventions, contrasting the OECD Model’s residence‑based approach with the UN Model’s source‑based philosophy. Through concrete examples on permanent establishments, royalties and services, the speakers illustrated how modern treaties blend elements of both models rather than operating as separate regimes.

The discussion also turned to recent treaty trends: while the OECD Model has long dominated, the UN Model’s provisions, especially those expanding source‑state taxation rights, are appearing more frequently in new agreements. This raises a critical question for practitioners: is the international tax architecture still essentially OECD‑centric, or are we witnessing the emergence of a polycentric system where both models coexist and influence each other?

We thank CLEON Conferences & Communications for organizing such a stimulating event, and we look forward to continuing the dialogue on the evolving dynamics of international Tax Law.