treaty interpretation
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Jonathan Schwarz (Temple Tax Chambers; King’s College London) for
OECD Commetary, permanent establishment, treaty interpretation
July 24, 2025
The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…
Jonathan Schwarz (Temple Tax Chambers; King’s College London) for
article 3(2), treaty interpretation, burden of proof, OECD Commetary, UN Commentary
November 3, 2022
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…