7/10/2025 1:24:26 PM There’s only one POEM – but it’s not of the rhyming sort! By Zoe Andrews The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation....
1/20/2022 4:34:07 PM A question of substance – a first look at the EU Commission's "Unshell Proposal" By Isabella Zimmerl Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax...
12/23/2021 10:25:43 AM The “Danish cases” controversy: the Spanish Tax Authority makes its move By Miguel Cremades Schulz Following the path of tax audits stemming from the ECJ’s rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax...
6/29/2021 2:56:32 PM Spanish National Court follows CJEU in placing burden of proving abuse on Spanish tax authorities By Guillermo Canalejo David López In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish...
5/14/2021 12:00:00 AM Supreme Court confirms (again) that Ramsay is a principle of statutory construction By Zoe Andrews We all love a good Ramsay case. Particularly one from the Supreme Court which does not upset the apple cart and require a re-learning of...
3/11/2020 12:00:00 AM Getting it done: the UK's March 2020 Budget By Tanja Velling Whilst the Budget was dominated by the announcement of a multi-billion pound economic stimulus to deal with the economic impact of...
3/2/2020 12:00:00 AM The Cayman Islands, Palau, Panama and the Seychelles listed by the European Council as non-cooperative jurisdictions By Darya Budova On 18 February, the Council extended the list of non-cooperative jurisdictions for tax purposes to the Cayman Islands, Palau, Panama and...
11/26/2019 12:00:00 AM Labour's Fair Tax Programme: the £6.2bn question... By Mike Lane ...or "Seeing as everyone else is now giving 'fact-checking a go'". When Labour published its 2019 Election manifesto last week it was...
7/23/2019 3:29:28 PM UK implementation of DAC 6 By Zoe Andrews The draft regulations to implement EU Directive 2018/822 (DAC 6) in the UK have been published alongside a consultation document. HMRC...
5/10/2019 12:00:00 AM Raising the bar for obtaining Dutch tax rulings By Maarten van der Weijden It is likely that the number of international tax rulings granted in the Netherlands will reduce significantly as a result of a new...
4/30/2019 12:00:00 AM Read your tax rulings carefully..... By Slaughter and May A recent UK tax tribunal decision, relating to the UK corporation tax treatment of a “tower” structure, serves as a useful reminder of...