8/18/2025 8:44:25 AM PepsiCo case comes to an end: Australian High Court calls last drinks and closes the bar By Angelina Lagana Craig Boyle In a much anticipated, eagerly awaited decision, the Australian High Court today, in a 4/3 majority judgment in Commissioner of Taxation...
7/2/2024 1:46:27 PM Pepsi wins royalty withholding tax and diverted profits tax appeal against the Australian Taxation Office By Andy Bubb On 26 June, Australia's Full Federal Court decided in favour of Pepsi on appeal, flipping the initial decision which had been in favour...
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...
11/5/2020 3:40:03 PM The Spanish Supreme Court stands as the latest pacta sunt servanda watch By Ángel Viñas The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the...
4/15/2020 11:56:57 AM New Luxembourg bill on payments to EU ‘black-list’ countries By Thierry Lesage Alain Goebel On 30 March 2020, the Luxembourg government filed Bill of law No 7547 implementing certain guidelines approved by the EU Council on 5...
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...