Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
DTTs
A double taxation treaty (DTT) is an agreement made between (usually) two jurisdictions which allocates taxing rights in relation to various items of income or gains between them. A DTT is designed to reduce juridical double taxation typically by eliminating or limiting taxation in the country in which the income or gain arises (source state taxation) or by requiring the country in which the person subject to taxation is resident to grant relief for source state taxation through a credit or exemption mechanism. A DTT commonly applies to residents of one or both of the contracting states and deals with specified taxes.
There have been a number of recent cases concerning the application of DTTs: Royal...
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Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
DTTs
A double taxation treaty (DTT) is an agreement made between (usually) two jurisdictions which allocates taxing rights in relation to various items of income or gains between them. A DTT is designed to reduce juridical double taxation typically by eliminating or limiting taxation in the country in which the income or gain arises (source state taxation) or by requiring the country in which the person subject to taxation is resident to grant relief for source state taxation through a credit or exemption mechanism. A DTT commonly applies to residents of one or both of the contracting states and deals with specified taxes.
There have been a number of recent cases concerning the application of DTTs: Royal...
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