The United Kingdom First-tier tax Tribunal has declined to order the disclosure of a US parent company's group consolidated financial statements and US entity level financial statements in a…
In an era where tax administrations seek increasing amounts of information from taxpayers and others, and where the routinely exchange information with each other, a recent decision of the European…
The recent decision of the Federal Court of Canada in Canada (National Revenue) v. Shopify Inc. (2025 FC 968) is a rare decision on the Joint Council of Europe/OECD Convention on Mutual…
The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…
The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…
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…
Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…
"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass)
Prior to the OECD…
Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet…
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…
