Tax treaties

The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Alice Pirlot, Climate Clubs: An International Tax Law Perspective Global…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Reuven Avi-Yonah, Do Intangibles Fit BEFIT? This article argues that the…

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…

The transition from bilateralism to multilateralism in regard of international law-making seems to be a relentless work in progress. Nobody contests that multilateralism would be – legally speaking –…

“Mirror, mirror, on the wall, who’s the fairest of them all?” – Brothers Grimm, “Snow White” Where it all started Tax evolved like many things in the world we experience today. Taxes were already…

George Orwell's parable, Animal Farm, offers insights on political and governmental institutions that bear revisiting from time to time. BEPS Action 6 with the broad title “Prevent treaty abuse” has…

After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax treaties (last…

In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25, 2015, in the Vienna University of Economics and Business (see invitation here). I…