Articles

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  Could transfer pricing adjustments and interest-free loans lead to dividend income characterization under tax treaties?
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  Swiss landmark decision: Could a company's ultimate parent entity be regarded as a 'shareholder' for tax treaty purposes?
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  Could share buy-back proceeds be characterized as dividend income for tax treaty purposes?
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  Art. 10 (Dividends): Indian ITAT’s special bench decision on dividend distribution tax (DDT) – why is it likely to be reversed by a High Court?
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  “May be taxed” versus “shall be taxed” in tax treaty context: A landmark court decision from Canada
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  Art. 4(1) and ‘the liable to tax requirement’: Some landmark court decisions from Belgium and Canada
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  Non-discrimination provisions in tax treaties: A landmark Canadian decision on post-amalgamation loss carry-forward
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  Can consideration for outright transfer of know how be characterized as royalty under an applicable tax treaty?
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  Danish Supreme Court’s interesting decision on income characterization: Business profits or income from immovable property?
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  Permanent establishment (PE) and disposal test: Existence of PE denied on the basis of the ‘Formula One Case’
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  MFN clauses in tax treaties: The Indian ITAT reads the 'make available' requirement from India-Portugal tax treaty into the India-Sweden tax treaty
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  Income characterization issues under tax treaties: some landmark judicial precedents
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  Construction PE in case of multiple projects: Stand-alone or aggregate approach?
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  Prerequisites for dependent agency PE under tax treaties: Some important judicial precedents
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  Variable interest on loans: Tax treaty characterization as dividends (Art. 10) or interest (Art. 11)?
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  Article 7 (Business profits) controversy: Independent enterprise hypothesis – are the courts’ approaches in various jurisdictions consistent?
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  Permanent Establishment: Does dependent agency permanent establishment provision in a tax treaty override Art. 5(1)?
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  Prerequisites for existence of a dependent agency PE: must be examined from the perspective of the agent or the principal?
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  Installation permanent establishment provisions in tax treaties: do they apply to computer software installation activities?
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  Can a permanent establishment (PE) exist as per Art. 5(2) of tax treaties even if the prerequisites of a PE under Art. 5(1) are not satisfied?
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  Art. 10(2) of tax treaties: Can a person owning dividend coupons (but not the underlying shares) be regarded as beneficial owner of the dividend income?
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  Dividend income in total return swaps (derivative) transactions: Is the beneficial ownership requirement satisfied?
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  Austrian Supreme Administrative Court on ‘center of vital interests’: What matters more, personal or economic connections? [Art. 4(2) of the tax treaties]
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  Art. 4(1) of tax treaties and ‘the liable to tax condition’: does it require actual payment of tax in the Residence State?
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  Art. 4(1) of tax treaties: residence-based taxation versus source-based taxation
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