Vienna Convention on the Law of Treaties

It has been 60 years since publication of the OECD 1963 Draft Double Taxation Convention on Income and Capital. That model has provided the core and structure of all subsequent model double tax…

English may be the lingua franca of our time, but it is not the only language of international law. Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC).  raised issues around the interpretation of a tax…

G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC)  raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence  under…

The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good…

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…

In last month’s blog I promised to address the treaty aspects of  Davies and Others v HMRC [2020] UKUT 67 (TCC). The case concerned UK resident individuals who each took out a life insurance policy…

Earlier this month, the author of this blog was at the IFA UK branch meeting where experts assembled to discuss certain interpretational aspects concerning the BEPS Multilateral Instrument (BEPS MLI)…

The High Court of Kenya gave judgement on 15 March 2019 on a challenge to the validity of the Kenyan-Mauritius double tax treaty in Tax Justice Network- Africa v Kenya Revenue Authority and others. …

Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…