The decisions of European Court of Justice (CJEU) in the Vodafone and Tesco cases[1] were eagerly awaited by many interested in EU tax law. It was expected that the CJEU would answer the question…
Revised transfer pricing legislation set out in the Finance Act 2019 (No 45 of 2019), sections 24 to 27, represents a radical shift in the Irish approach to this area of international tax law…
Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…
May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was…
The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should…
