International Tax Law

Robert Danon (Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA))

The effectiveness of the Mutual Agreement Procedure and the global tax controversy landscape: some critical observations on current pressure areas and suggestions to improve the framework

May 28, 2025

IntroductionOn 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

No abusive treaty-shopping of Caricom multilateral tax treaty

May 22, 2025

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 …

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Transfer Pricing corresponding adjustments as of right

April 8, 2025

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…

Raymond Luja (Maastricht University)

The U.S. pushback on minimum corporate tax rates may test the limits of bilateral tax treaties with EU Member States

February 18, 2025

*This post was first published on the website of Maastricht University* In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Just how far does the AOA go?

February 5, 2025

"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…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Credit where credit is due

January 7, 2025

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…

Ricardo Garcia Anton (Assistant professor of International and European Tax Law at, Fiscal Institute Tilburg, Tilburg School of Economics and Management, Tilburg University.)

Tax Exceptionalism – Should Tax law converge/diverge with other legal disciplines?

July 8, 2024

Ricardo García Antón* The rapid developments in international taxation in the aftermath of the latest financial crisis (2010s), i.e. the fight against tax evasion and tax avoidance, the Pillars’ work…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Beneficial ownership and abuse – even more

May 31, 2024

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…

Natalia Quinones (Quiñones Cruz Abogados)

The UN Framework Convention On Tax Matters And A New Hope For Multilateralism And Simplification In The Area Of International Taxation

April 3, 2024

Resolution 78/230 was approved by the United Nations General Assembly in December, 2023, creating a mandate for an ad-hoc committee inclusive of all UN member states to draft the terms of reference…