Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of…
The Tax Court of Canada decision in Alta Energy Luxembourg S.A.R.L. v. The Queen, 2018 TCC 152 (CanLII) on August 22, 2018 may provide useful pointers to the meaning and application of the PPT found…
Article 13.1 of the double tax treaty (DTT) signed between Luxembourg and Spain authorizes Spain to tax gains from the alienation of shares in a company whose assets consist principally of immovable…
