The recent English Court of Appeal decision in Hargreaves Property Holdings Ltd v HMRC [2024] EWCA Civ 365 http://www.bailii.org/ew/cases/EWCA/Civ/2024/365.html has again examined the meaning of…
In my previous blog I examined the Tax Court of Canada’s analysis of the meaning of beneficial ownership in tax treaties in Husky Energy Inc. v The King, 2023 TCC 167 in relation to stock or…
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…
The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good…
When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…
International double taxation should be to European VAT harmonization what tropical temperatures should be to the polar regions: a challenge of the natural laws of the universe and, at the same time,…
