Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…
In the first part of this article, the authors provided an overview of the Blackrock case. In the second part of this article, the authors consider the DBKAG case and reflect on the impact that these…
In this article, which is divided in two parts, the authors consider two judgments from the Court of Justice of the European Union (CJEU) in respect of the VAT exemption for the management of funds…
