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European Tax

4 results for: oecd commentaries

Amsterdam Appeal Court: what are the limits to using post-dated OECD commentaries in interpreting a double tax treaty?

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...

French Administrative Supreme Court takes post-dated OECD commentaries into consideration in interpreting French-Irish double tax treaty

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...

To what extent can post-dated OECD commentaries be taken into account in interpreting a double tax treaty?

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...

Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent”

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...