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....
1/30/2025 9:52:45 AM Joint ventures and the top-up taxes: does HMRC's draft guidance bring clarity? By Stephanie Mullins HMRC published supplementary draft guidance on the Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) covering, among other...
9/27/2023 1:34:09 PM Where are you on Pillar Two? By Zoe Andrews Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...