How will COVID-19 affect the future of environmental taxes?
Whilst the impact of COVID-19 on the environmental taxes agenda is yet to be fully understood, it would seem prudent for businesses to...
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How many hammers are needed to crack a nut?
The ‘cum-ex scandal’ being the nut in question here. After a consortium of journalists uncovered schemes generating multiple refunds of...
How far does the fiction of a deeming provision extend?
Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC....
Dutch tax treatment of intra-group debt guarantees at odds with OECD guidance
The paragraph of the OECD transfer pricing guidance on financial transactions dealing with parent guarantees is, in my view, incompatible...
No fixed establishment through parent-subsidiary relationship
Or at least not automatically. A company established outside the EU does not have a fixed establishment for VAT purposes in an EU Member...
Partnership taxation: still a work in progress?
Given the general view of partnership taxation – “they’re just transparent, right?” – it is somewhat surprising that how a partnership...
Trust recognised as a “person”, but fails to get treaty benefits
A UK trust is a “person” for the purposes of the Italy-UK double tax treaty - that is the good news coming out of a recent Italian...
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