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 …
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…
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…
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…
1. Background
In the article Is the Multilateral Instrument (MLI) Really Multilateral? published in the book A Multilateral Convention for Tax – From Theory to Implementation of the Wolters Kluwer…
Notes on the starting of MLI internalization process
Background
The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI) [i]…
G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC) raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence under…
When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…
Denmark accepted all MLI articles dealing with PEs, but what does that actually mean? Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles…
