Tax Treaties

The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good…

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)…

In international customary law, the scope of bilateral tax conventions is not exhaustive and instead limited by the temporal scope set out in ‘taxes covered’ clause. It is true that the scope of such…

Those with a long memory for cricketing events may remember the 1996 World Cup hosted jointly by India, Pakistan and Sri Lanka. The winner, Sri Lanka, made 398 runs for 5 wickets, in a one-day…

A couple of days ago, in the last weekly session of the Indiana-Leeds Summer Tax Workshop, I attended the presentation of a fascinating paper by Steven A. Dean (A Constitutional Moment in Cross…

Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has considered another case where classification of a source of income for tax treaty purposes was in…

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…

We have all become familiar with the expression in the PPT set out in article 7(1) of the MLI and article 29(9) of the 2017 OECD Model  where “obtaining that benefit was one of the principal purposes…

With a judgment rendered on 16 December 2019 (case no. 2C_209/2017), the Swiss Federal Supreme Court (“FSC”) rejected several reclaims of Swiss dividend withholding taxes made by a Luxembourg…