In an era where tax administrations seek increasing amounts of information from taxpayers and others, and where the routinely exchange information with each other, a recent decision of the European…
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…
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…
