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 is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…
1. Introduction
To be able to compete successfully in international markets, companies need to turn their R&D results fast and effectively into marketable products. Thus, besides the development …
Introduction
India’s 2021 Finance Bill proposes to add a definition of “liable to tax” in its domestic direct tax law. As per the definition, the term ‘liable to tax’, “in relation to a person, means…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
With a judgment rendered on 27 November 2020 (case no. 2C_835/2017), the Swiss Federal Supreme Court (“FSC”) confirmed a decision by the Federal Administrative Court (“FAC”) of 24 August 2017 …
The Revenue Agency confirms the exemption of income derived abroad by foreign maritime employees who are tax residents of Italy
The Italian Revenue Agency has recently issued a ruling (No. 134/2020)…
Tax Issue Under Review
On 6 February 2020 (case no. 2C_510/2018), the Swiss Federal Supreme Court rendered a decision on the tax qualification of a pension plan benefit paid from a Swiss pension plan…
The COVID-19 pandemic has led to unprecedented times for the world. Many countries, including India, most of Western Europe and some states of the US have now imposed mandatory lockdowns, in addition…
