Introduction
In two previous posts on this blog (1 and 2), the author analyzed the VAT treatment of activities carried out by public entities, particularly public entities that offer radio and…
Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium
Raphaël Devroye – Transfer Pricing Manager at PwC Belgium
In a recent judgement[1], the Belgian Court of Appeal of…
Apropos Molinos Rio de la Plata SA
1. Background: Memorandum DNI 799/10
In Memorandum 799/10, the Argentine Competent Authority (Argentine Tax Directorate, Dirección Nacional de Impuestos or DNI)…
Omar Sebastian Cabrera [1]
General considerations
Law 2133, dated August 4, 2021, implemented a new tax regime related to the flagging of ships and vessels in Colombia. The purpose of this law is to…
In the first part of this article, the authors provided an overview of the Blackrock case. In the second part of this article, the authors consider the DBKAG case and reflect on the impact that these…
Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC [2021] UKFTT 210 (TC). This…
In this article, which is divided in two parts, the authors consider two judgments from the Court of Justice of the European Union (CJEU) in respect of the VAT exemption for the management of funds.…
On 20 May, 2021 the first Webinar of IFA’s online series “A conversation on International Tax Practice” was held. Chaired by Robert Danon (Chair IFA Permanent Scientific Committee), global…
In one of the significant and eye-catching moves by the Indian government, the controversial law on retrospective tax on indirect transfer of shares representing assets held in India was withdrawn…
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…
