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,...
6/6/2024 2:09:54 PM Good news for secondary debt markets in interest withholding tax case before UK Upper Tribunal By Zoe Andrews HMRC v Burlington Loan Management DAC is an important decision for the smooth running of secondary debt markets. It is also a helpful...
5/4/2023 9:39:01 AM The French Administrative Supreme Court provides clarifications on the French CFC regime in a non-EU context By Yves Rutschmann Victor Camatta In a decision dated 25 April 2022, the French Administrative Supreme Court has provided useful clarifications on the French CFC regime...
11/23/2022 10:26:50 AM Interpreting tax treaties - Dutch Supreme Court clarifies relevance of later OECD commentaries By Mees Vergouwen In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage...
4/10/2021 8:32:16 AM Amsterdam Appeal Court: what are the limits to using post-dated OECD commentaries in interpreting a double tax treaty? By Maarten van der Weijden The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of...
4/9/2021 10:49:08 AM French Administrative Supreme Court takes post-dated OECD commentaries into consideration in interpreting French-Irish double tax treaty By Yves Rutschmann Victor Camatta In its decision in the Valueclick Case on 11 December 2020, the French Administrative Supreme Court ruled on the existence of a permanent...
4/8/2021 1:05:58 PM To what extent can post-dated OECD commentaries be taken into account in interpreting a double tax treaty? By Maarten van der Weijden Yves Rutschmann Victor Camatta This question - which is of utmost importance as the OECD commentaries provide key insights to tax authorities, taxpayers and judges, on...
12/14/2020 12:00:00 AM Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent” By Victor Camatta Pierre-Marie Roch In a decision dated 11 December 2020 (no 420174), the French Administrative Supreme Court (Conseil d’Etat) overturned the decision of the...