The decision of the CJEU in Republic of Austria v Federal Republic of Germany (Case C-648/15) on 12 September 2017 is a landmark decision in tax treaty dispute resolution. Han Verhagen raised…
On 24 April 2017 the Indian Supreme Court held that Formula One World Championship Ltd, the holder of the commercial rights to the Formula One Grand Prix, had a permanent establishment in India at…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19…
