The recent decision of the Federal Court of Canada in Canada (National Revenue) v. Shopify Inc. (2025 FC 968) is a rare decision on the Joint Council of Europe/OECD Convention on Mutual…
It has been 60 years since publication of the OECD 1963 Draft Double Taxation Convention on Income and Capital. That model has provided the core and structure of all subsequent model double tax…
Luisa Scarcella (DigiTax Centre at University of Antwerp; Member of the Working Party on Tax & Legal Matters)
The recent rise in the price of Bitcoin and other cryptocurrencies and crypto-assets…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
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…
Marcos Álvarez Suso (Auditing Department of the Spanish Tax Authorities)
The digital economy in the 21st century
New business models associated to the so-called digital economy are blossoming in all…
