In a recent post, Professor Werner Haslehner raised an interesting discussion on the new wording of Article 4.1 (a) of the Parent-Subsidiary Directive (“PSD”), which obliges the Member State of the…
In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a common set of rules that govern the…
This week, the United Kingdom Supreme Court, in a landmark decision, has ruled that a UK resident individual member of a Delaware limited liability company is entitled to credit in the UK for US tax…
