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…
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…
For some time now, Poland and Hungary have been under scrutiny from the European Commission for their violation of the rule of law, as we read with some regularity in the daily press. Recently,…
