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 …
The recent English Court of Appeal decision in Hargreaves Property Holdings Ltd v HMRC [2024] EWCA Civ 365 http://www.bailii.org/ew/cases/EWCA/Civ/2024/365.html has again examined the meaning of…
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…
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…
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…
Case law on thepurpose of transactions is starting to develop around the world. Is there a common pattern?
Whether a financing structure was a “tax avoidance arrangement” under now repealed general…
Inspiration, purpose and the context of this contribution
In the article “The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!”, Professor Robert Danon convincingly demonstrated that …
In a moment of crisis like the one provoked by the Coronavirus, the problems of tax avoidance and tax evasion become particularly relevant, even more when they are blamed for cutting national…
In last month’s blog I promised to address the treaty aspects of Davies and Others v HMRC [2020] UKUT 67 (TCC). The case concerned UK resident individuals who each took out a life insurance policy…
