International Tax Law

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

Permanent Establishment: Welcome to the Hotel California*

September 16, 2025

The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…

Duco ter Steege (Corporate income tax specialist at the Dutch Tax Administration)

Tax incentives everywhere: what will come of it?

September 15, 2025

1. IntroductionEarlier this year, the 2024 update of the OECD Investment Tax Incentives Database (ITID) was published. The ITID provides useful information on the design, eligibility and governance…

Mees Vergouwen (Assistant professor at Leiden University and tax advisor at KPMG Meijburg & Co)

The reference for a preliminary ruling on the compatibility of the UTPR with primary EU law and customary international law: a comment

September 10, 2025

On 17 July 2025 the Belgian Constitutional Court requested a preliminary ruling from the Court of Justice of the European Union (CJEU) regarding the compatibility, and by extension the validity, of…

Jonathan Schwarz (Temple Tax Chambers; King’s College London) for OECD Commetary, permanent establishment, treaty interpretation

Paper does not give rise to a Permanent Establishment

July 24, 2025

The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…

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…