private equity
2 articles available
Jonathan Schwarz (Temple Tax Chambers; King’s College London) for
OECD Commetary, permanent establishment, treaty interpretation
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…
May 7, 2019
Some issues tax issues never go away. The source of income or gain is one of them. Two recent decisions, one Australian, and the other South African, have considered this fundamental issue. Both…