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 …
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…
In its judgment of January 21, 2020 (Santander case, available here), the European Court of Justice (ECJ) not only prevented the Spanish Central Tax Tribunal (Tribunal Económico-Administrativo…
The VAT treatment of the issue, acquisition, holding and sale of shares has become a rather complicated affair over the last thirty years. The case law of the Court of Justice of the European Union …
