8/18/2025 8:44:25 AM PepsiCo case comes to an end: Australian High Court calls last drinks and closes the bar By Angelina Lagana Craig Boyle In a much anticipated, eagerly awaited decision, the Australian High Court today, in a 4/3 majority judgment in Commissioner of Taxation...
8/15/2025 8:18:04 AM Applying tax treaties to pensions payments: the First-tier Tribunal’s decision in Masters By Tanja Velling Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in...
8/11/2025 10:40:10 AM Italian tax on dividends contrary to Parent Subsidiary Directive: details and implications By Michele Dimonte Dividends received by Italian financial intermediaries (including banks) from their subsidiaries are subject to Italy’s regional tax on...
8/6/2025 10:35:18 AM HMRC’s procedural blunder: How far does the UK Supreme Court’s decision in Zipvit go? By Tanja Velling Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...
8/1/2025 8:49:36 AM UK inheritance tax changes will add to administrative burden on pension schemes By Karen Mumgaard In October 2024, the UK Government announced as part of the budget that from 6 April 2027, “inherited pensions [will be brought] into...
7/10/2025 1:24:26 PM There’s only one POEM – but it’s not of the rhyming sort! By Zoe Andrews The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation....
7/1/2025 2:01:51 PM Section 899 compromise shifts international tax landscape By Zoe Andrews Tanja Velling The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...
7/1/2025 9:25:42 AM French Digital Services Tax under Constitutional Review: Key opportunities and deadlines for taxpayers By Pierre-Henri Durand Ronan Vallerie Victor Camatta On 17 June 2025, the French Administrative Supreme Court (Conseil d’État) referred a preliminary question on the constitutionality of the...
6/26/2025 2:22:28 PM Vietnamese jets and double tax treaties By Max Cheung What can an aircraft leasing case tell us about the interpretation of tax treaties? Quite a bit, as it turns out. In VietJet Aviation,...
6/25/2025 3:53:29 PM UK Supreme Court in Dolphin Drilling decides that the meaning of “incidental” depends on statutory context By Zoe Andrews The Supreme Court in Dolphin Drilling dismissed the taxpayer’s appeal, agreeing with the Court of Appeal that the provision of...
6/10/2025 10:27:55 AM Re-domiciliations and cross-border mergers: key tax questions By Victor Camatta Tanja Velling Re-domiciliations and cross-border mergers can be great options for a restructuring and, within the EU, the rules governing both types of...
6/4/2025 9:10:40 AM FATCA data transfers incompatible with GDPR according to the Belgian Data Protection Authority By Lily Latimer Smith On 24 April 2025, the Belgian Data Protection Authority (DPA) ruled (once again) that transfers of personal data by the Belgian Federal...
5/2/2025 2:19:03 PM Transfer pricing, permanent establishment and diverted profits tax reform – draft legislation By Alex Sim Gianni Prenol As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft...
4/28/2025 3:58:18 PM UK tax changes on the horizon By Tanja Velling How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax...
4/15/2025 3:59:21 PM Court of Appeal in WTGIL case holds insurance intermediary provides a single exempt supply By Zoe Andrews Young drivers can get a specialised form of motor insurance if they have a device fitted to the car which records and transmits...
3/26/2025 5:24:21 PM UK Spring Statement 2025: No fiscal event, but some developments of interest By Tanja Velling The UK’s Spring Statement delivered on 26 March 2025 did not include further tax increases and the Chancellor stuck to her commitment to...