Some issues tax issues never go away. The source of income or gain is one of them. Two recent decisions, one Australian, and the other South African, have considered this fundamental issue. Both…
The High Court of Kenya gave judgement on 15 March 2019 on a challenge to the validity of the Kenyan-Mauritius double tax treaty in Tax Justice Network- Africa v Kenya Revenue Authority and others. …
The judgements of the CJEU in N Luxembourg 1 v Skatteministeriet (Case C-115/16) and joined cases and in T Danmark (Case C-116/16) and another joined case, on 26 February 2019, once again addressed…
The Tax Court of Canada decision in Alta Energy Luxembourg S.A.R.L. v. The Queen, 2018 TCC 152 (CanLII) on August 22, 2018 may provide useful pointers to the meaning and application of the PPT found…
The update on tax certainty IMF/OECD Report for the G20 Finance Ministers and Central Bank Governors published on 22 July 2018 may not have been everyone’s summer holiday reading. This report…
What the UK government wants by way of Brexit outcome seems to change daily, with the government and political parties in Parliament divided among various factions. The only legal certainty about…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
“Those who cannot remember the past are condemned to repeat it” George Santayana, The Life of Reason: Reason in Common Sense (1905).
A seminar was held in Rotterdam on 18 May 2018 on “value creation…
There is only one legal certainty about Brexit. On 29 March 2019 EU law will cease to apply in the United Kingdom, as a result of the UK having given notice of withdrawal on 29 March 2017. This is…
Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…
