IntroductionThe application of the beneficial ownership limitation in double taxation conventions (“DTCs”) continues to be a key area of focus in tax treaty disputes. Moreover, court decisions giving…
IntroductionOn 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax…
Prof. Dr. Robert J. Danon, University of Lausanne /DANON /Prof. Dr. Adolfo Martín Jiménez, University of Cádiz/AMJ ITC
On 24-27 March 2025, the United Nations Committee of Experts on International…
Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice
Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín…
Recently, national courts of several EU member States (notably France[1], Italy[2], the Netherlands[3] and Spain[4]) referred to the landmark judgments of the Court of Justice of the European Union (…
