Article 13.1 of the double tax treaty (DTT) signed between Luxembourg and Spain authorizes Spain to tax gains from the alienation of shares in a company whose assets consist principally of immovable…
Following up on Jonathan Schwarz’s latest blog contributing to the debate on taxation and value creation, I wanted to attempt adding some further critical points. The OECD’s stated goal of the second…
The May issue of Intertax is already available online here. The online reader can now identify the different sections, which include, besides the articles, an editorial, debate, country and case-law…
The importance of the permanent establishment (PE) principle in tax treaties cannot be undermined. Whether or not a source country has the right to tax business profits of a foreign company would…
Introduction
This is the second part of the input dealing with the MLI’s LOB rule. It focuses on the second and the third subtests under the MLI’s LOB rule, i.e. the concept of income emanating from…
“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…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Eric C.C.M. Kemmeren, A Global Framework for Capital Gains Taxes…
Introduction
This is the first part of the input regarding the MLI’s LOB. It addresses the active conduct of a business, which constitutes the first subtest under the MLI’s LOB rule. The second part…
On 25 September 2015, the UN General Assembly adopted the historic resolution Transforming our world: The 2030 Agenda for Sustainable Development. The agenda calls upon all 193 UN member states to…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Michael Lang, Double Taxation Conventions in the Case Law of the CJEU…
