9/18/2025 9:30:11 AM Can you rely on a tax treaty to progress an HMRC enquiry? By Sarah Osprey Zoe Andrews Tanja Velling If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what...
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...
2/13/2025 4:28:15 PM A question of interpretation: the UK Supreme Court’s decision in Royal Bank of Canada By Zoe Andrews All has ended well for the Royal Bank of Canada (RBC) following the Supreme Court’s majority decision (4:1) that the UK does not have...
2/7/2025 2:23:39 PM Management fees in tax treaties: a ménage à deux between Italy and Egypt By Michele Dimonte Mostafa Elfar The Italian tax authority (ITA) ruling (13/2025) concerned an Italian company that provided IT services to a company resident in Egypt....