United Nations

Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5…

The most recent UN Climate Change Conference in Glasgow, or COP26, attracted the attention of long-term investors. The reason for that was the announcement of the International Financial Reporting…

G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC)  raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence  under…

1. Background During the 21st Session of the UN Committee of Experts on International Cooperation in Tax Matters, the relevant members decided to include a new draft - Art. 12B on Automated Digital…

There's something about OECD's Pillar One. For some years now, the world has been under the spell of a new system of taxation of companies that make profits in countries without taking root there in…

This article is the last of a series of three posts dealing with non-chargeable intra group services: Shareholder Activities, Duplicate Activities and Incidental Benefits. This post will specifically…

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…

Duplicate activities? Duplicate services are defined in the 2017 Transfer Pricing Guidelines (TPG) of the OECD as “activities undertaken by one group member that merely duplicate a service that…

Measures to prevent the spread of coronavirus have impacted on every aspect of life. While the degree of enforced isolation and immobility varies from country to country, the basic elements remain…