The relationship between treaties and domestic tax law ought to be straightforward. The pacta servanda sunt principle expressed in articles 26 and 27 of the Vienna Convention on the Law of Treaties…
There are several misconceptions in international taxation, some of them more pervasive than others. Many are often repeated by speakers at tax conferences without being contradicted.
The first is…
In many European countries, the question of legal personality has relevance for determining the transparent character of a business entity for tax purposes and this assessment is even more complex…
