European Tax

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....

After a chaotic process marked by the no-confidence vote of the Government formed by the French Prime Minister Barnier in December 2024...

On 16 October 2023 the Italian Government preliminarily approved a legislative decree to implement a reform regarding international...

The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on...

The last few months have, I think, made it clear that there will be no single sweeping return to "normal". However, as restrictions start...

Disregarding the spirit of the OECD guidance on how to deal with COVID-19 exceptional circumstances, the Spanish tax authorities have...

Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD)...

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...

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...

HMRC has issued guidance providing some comfort in respect of the question whether employees who do not normally work in the UK, but are...

Travel restrictions imposed in response to COVID-19 may impact a director's ability to travel to Ireland in order to attend board...

’Social distancing’ measures and ‘lockdowns’, introduced to reduce the spread of COVID-19, involve restrictions on travel – with a...

The French Draft Finance Bill for 2020, as published on 27 September, includes a provision introducing a presumption that individuals...

In her recent post, Tanja Velling highlights some of the uncertainties in the UK around the tax residence of a company. This is not just...

The First-tier Tax Tribunal's unhelpful decision in the Development Securities case has been reversed by an Upper Tribunal decision which...