Withholding Taxes

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…

Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…

Tax Administration Announces New Control Project The Finnish Tax Administration has announced that it will be tackling arrangements to avoid withholding tax on dividends. According to the Tax…

Equality is one of the core values of modern democratic societies. It is no accident that equality featured in opening preamble to the United States Declaration of Independence in 1776 and the first…

The judgments of the European Court of Justice (ECJ) on the withholding tax exemption provided by the Interest and Royalties Directive (available here – the ‘IRD judgment’) and the Parent-Subsidiary…

Taxation of the digital economy has become a war in the post-BEPS world. As with any war, there are more or less clear rivals and there will be of course winners and losers. It goes without saying…

Almost every foreign client I have advised has at some stage told me how complex the Indian Income Tax Act is. And those who follow Indian tax jurisprudence closely know that judicial decisions, in…

Being familiar with the Spanish tax environment, readers will know that Spain does not withhold taxes on interest paid to EU residents. This domestic exemption has been in force for several decades,…

Taxation of the digital economy featured in discussion on the implementation of the OECD/G20 BEPS action items at the annual conference of the Canadian Tax Foundation in Toronto on 21 November 2017…