International Tax Law

A widely accepted view in contemporary tax literature is that international taxation is increasingly shifting toward multilateralism. This article argues that the current evolution reflects not the…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:Debate: The Normative Case for a Global Minimum Tax on Ultra-High-Net-Worth…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:A Defence of UTPRThis article defends UTPR (formerly known as the Under Taxed…

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…

 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…

  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…

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…

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…

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 …