4/29/2021 12:00:00 AM Japan and Spain update their double taxation treaty: no withholding on dividends, interest and royalties By Carlos García-Olías Santiago Tórtola Japan and Spain have signed a new tax treaty in connection with income taxes and to prevent tax evasion and avoidance (the “Treaty”). The...
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...
11/10/2020 10:38:10 AM IP taxation: German nexus in unexpected circumstances By Sebastian Heinrichs The German Ministry of Finance (BMF) published the first guidance on one of the most hotly discussed German tax issues of the year on...
5/7/2020 1:21:23 PM When is a resident not a resident? By Mike Lane It sounds like a bad joke, befitting of a tax lawyer in lockdown, but is really just a reminder to check the small print in double tax...
5/7/2020 11:16:27 AM Trust recognised as a “person”, but fails to get treaty benefits By Andrea Manzitti 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...
11/8/2019 12:00:00 AM The ORIP rules: intangible property held in the Crown Dependencies By Tomás McGrath It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies...
9/13/2019 4:16:19 PM A new Protocol will significantly amend the U.S.-Spain Tax Treaty By Guillermo Canalejo On 27 November 2019, the U.S.-Spanish Tax Treaty, which dates back to 1990, will be significantly amended by the entry into force of a...