English may be the lingua franca of our time, but it is not the only language of international law. Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC). raised issues around the interpretation of a tax…
Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has considered another case where classification of a source of income for tax treaty purposes was in…
Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of…
