double taxation

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Credit for foreign tax: the curious case of Paul Bruyea

October 8, 2026

The principal purpose of tax treaties is the avoidance of double taxation. Outcomes that result in double taxation inherently run contrary to that purpose. That appears to be the case in the recent…

Jonathan Schwarz (Temple Tax Chambers; King’s College London) for OECD Commetary, permanent establishment, treaty interpretation

Paper does not give rise to a Permanent Establishment

July 24, 2025

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…

Ligia Fonseca (Air Transport Association ), Gemma Giner (Air Transport Association)

Proposed changes to the UN Tax Model Convention – 10 reasons why Article 8 must be kept unchanged for airlines

October 12, 2023

The UN Tax Committee is currently considering revising the UN Model Double Taxation Convention between Developed and Developing Countries[1], particularly Article 8 (Alternative B), which relates to…

Ana Paula Dourado (General Editor of Intertax) for Intertax

The Contents of Intertax, Volume 51, Issue 03, 2023

February 28, 2023

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Leonie Fischer, Jessica M. Müller & Christoph Spengel, The Distorting…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Hidden or Accidental Permanent Establishments and Penalties

January 24, 2016

Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…