When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…
The present article explores some concrete application cases of Big Data in Tax Administrations (TAs). It then formulates some ideas for its possible expansion in the near future, considering both…
Tax authorities have relied on informers for investigative leads perhaps since taxes were first imposed. In the 21st Century high profile cases of theft of taxpayer information by employees of…
The Trade Agreement between the EU and the UK rules out any direct effect. However, the Trade Agreement could have an indirect effect. EU Member States should interpret the capital ownership…
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…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
The digitization and globalization of the economy have created a challenging environment to enforce tax rules and ensure tax compliance. Ever since the OECD’s release of the Action Plan on Base…
After the initial relief that followed upon reaching a Trade and Cooperation Agreement between the European Union and the United Kingdom on Christmas Eve, we slowly see how this treaty is going to…
With a judgment rendered on 27 November 2020 (case no. 2C_835/2017), the Swiss Federal Supreme Court (“FSC”) confirmed a decision by the Federal Administrative Court (“FAC”) of 24 August 2017 …
