Double Taxation

The Judicial Committee of the Privy Council (the highest appeal court for a number of Commonwealth countries) ruled  last month that payment rapid payment of dividends by a Trinidadian company …

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…

"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD…

Within hours of his appointment, Donald Trump issued a memorandum in which he rejects the Global Tax Deal conceived by the OECD/G20. The new US president stresses that it has "no force or effect…

Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet…

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…

Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158  and, for…

The UN Tax Committee is currently considering revising the UN Model Double Taxation Convention between Developed and Developing Countries[1], particularly Article 8 (Alternative B), which relates to…