United Kingdom

Those with a long memory for cricketing events may remember the 1996 World Cup hosted jointly by India, Pakistan and Sri Lanka. The winner, Sri Lanka, made 398 runs for 5 wickets, in a one-day…

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…

Revised transfer pricing legislation set out in the Finance Act 2019 (No 45 of 2019), sections 24 to 27, represents a radical shift in the Irish approach to this area of international tax law…

Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…

Equality is one of the core values of modern democratic societies. It is no accident that equality featured in opening preamble to the United States Declaration of Independence in 1776 and the first…

Some four years ago in this blog, I wrote about problems that would start to emerge as exchange of information between tax administrations became more routine and extensive.  If nothing else, the…

While earthlings are grappling with taxation in a digitalised world, a new and important frontier has been opening up somewhat less observed. Commercial exploitation of space has become commonplace…

Mutual agreement procedure (MAP) pursuant to article 25 of the OECD and UN Model treaties imposes obligations on tax administrations. Inadequacies in the performance of these obligations has been the…

The judgements of the CJEU in N Luxembourg 1 v Skatteministeriet (Case C-115/16) and joined cases and in T Danmark (Case C-116/16)  and another joined case, on 26 February 2019, once again addressed…