India recently notified a Protocol that amends the India-China tax treaty and incorporates some of the OECD recommendations put forth as part of its BEPS project. The changes would apply from the…
Not the Hungarian Constitutional Court but maybe AG Kokott in her forthcoming opinion in the Google Ireland case…
Optimistically speaking, the Hungarian Advertisement Tax contributes to a large…
Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD…
Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of…
Earlier this month, the author of this blog was at the IFA UK branch meeting where experts assembled to discuss certain interpretational aspects concerning the BEPS Multilateral Instrument (BEPS MLI)…
The Income Tax Appellate Tribunal (hereinafter referred to as the “Tribunal”), Mumbai delivered a landmark judgment in the case involving two parties namely, Elsevier Information Systems Gmbh and Dy…
Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51 addressed a number of fundamental international tax issues. The case concerned a gain from the sale of shares in an Australian…
Mutual agreement procedure (MAP) pursuant to article 25 of the OECD and UN Model treaties imposes obligations on tax administrations. Inadequacies in the performance of these obligations has been the…
The quest to align the international tax order with the challenges posed by the digital economy has so far mostly focused on solving issues involving incorporated structures. What is somehow escaping…
