Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.
Michael McGowan, Andrew Thomson and Emma Hardwick (Sullivan & Cromwell) review Action 6 of the BEPS report.
Peter Halford (PwC Legal) considers AG Kokott’s opinion in the ‘Austrian goodwill’ case, including its implications for the Commission’s appeals to the CJEU in the ‘Spanish goodwill’ cases.
Allan Cinnamon (Cintax the Word Ltd) reports on tax digital trading, applying treaty benefits to partnerships, PE preparatory and auxiliary exemptions and recent treaty highlights
Macklin v HMRC concerned where a pension plan was established for the purpose of double tax treaty relief. Jonathan Schwarz (Temple Tax Chambers) considers the case and its implications