International Tax Law

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…

*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…

"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…

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 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…

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…

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…

In my previous blog I examined the Tax Court of Canada’s analysis of the meaning of beneficial ownership in tax treaties in Husky Energy Inc. v The King, 2023 TCC 167 in relation to stock or…

AN INTRODUCTION IS IN ORDER As the new Managing Editor of the Kluwer International Tax Blog I have been asked to introduce myself to our audience.  Such an invitation is also an opportunity for self…