Part I. International treaty autonomous BO-GAAR relationship
“[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be…
Introduction
The present contribution aims at discussing two fundamental concepts often coming into play in the analysis of transactions between associated enterprises involving intangible property:…
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…
What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income?
The current version of the United Nations Model Double Taxation Convention…
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…
Does the helm of command over international tax policy shift to the United Nations? This is the scenario that could be envisioned following the Nov. 22 U.N. General Assembly that approved the…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Andrés Báez Moreno & Yariv Brauner, Pillar One and Alchemy: What Can We…
