Withholding Taxes

The Judicial Committee of the Privy Council (the highest appeal court for a number of Commonwealth countries) ruled  last month that payment rapid payment of dividends by a Trinidadian company …

The recent English Court of Appeal decision in Hargreaves Property Holdings Ltd v HMRC [2024] EWCA Civ 365 http://www.bailii.org/ew/cases/EWCA/Civ/2024/365.html  has again examined the meaning of…

In my previous blog I examined the Tax Court of Canada’s analysis of the meaning of beneficial ownership in tax treaties in Husky Energy Inc. v The King, 2023 TCC 167 in relation to stock or…

Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158  and, for…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More…

Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…

When India’s Finance Minister rose before the Lok Sabha (House of Commons) on 1st Feb, 2022 to present her budget for India’s fiscal year 2022-23 (April 1, 2022 to March 31, 2023), she compressed the…

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…

For a number of years, endeavors to reform the Swiss federal withholding tax system with regard to the taxation of interest from collective debt instruments have been going on. The reform is…