International Tax Law

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…

Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158  and, for…

Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…

It has been 60 years since publication of the OECD 1963 Draft Double Taxation Convention on Income and Capital. That model has provided the core and structure of all subsequent model double tax…

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Rachna Matabudul, The Multilateral Instrument in Africa: A Strategic…

“Oh, I was so happy when I was told you were in the panel!” It is always nice that someone is pleased with your presence, but this surprised me a bit. The OECD employee who made this confession had…

The very recent CJEU judgement in Berlin Chemie A. Menarini v Administraţia Fiscală pentru Contribuabili Mijlocii Bucureşti (Case C-333/20) ECLI:EU:C:2022:291, admirably examined by Giorgio Beretta…