Taxes are an unavoidable aspect of our lives and play a crucial role by shaping how a country grows and serves its people. Beyond being a financial obligation, taxes represent the primary source of…
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…
Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…
This is the second part of the authors' blog on the Proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT) that the European Commission (EC) published on 12…
This is the first part of the authors' blog on the Proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT) that the European Commission (EC) published on 12…
G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC) raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence under…
Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC [2021] UKFTT 210 (TC). This…
When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…
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…
