OECD Model article 26
3 articles available
3 articles available
My blogs in 2026 have examined cases where tax authorities’ requests for information, either for their own investigations or in connection with exchanges with other authorities, have been contested…
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…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…