Tax Treaty Case Law around the Globe 2021

Special offer
- Order the print together with any electronic format of the same title and receive a 20% discount on each format. The discount is calculated automatically in your shopping cart.
- Bulk discounts apply on orders of 10 or more books of the same format (this applies to each of the formats) with a maximum of 20% discount. The offer is not valid for resellers.
- Students are entitled to a 50% discount on IBFD books and 20% discount on third party books (valid student card required).
To obtain student discounts, contact Customer Support.
Online books
Access your online books on the Tax Research Platform.
Don’t have a Tax Research Platform subscription?
Learn more
This book covers the thirty most important tax treaty cases that were decided around the world in 2020.
Why This Book?
This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases.
With the continuously increasing importance of tax treaties, “Tax Treaty Case Law around the Globe 2021” is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.
Tax Treaty Case Law around the Globe 2021
DOI: https://doi.org/10.59403/2bsht9a
Go to Tax Research Platform
Austria: Supreme Administrative Court on a Hybrid “Sandwich Structure”
DOI: https://doi.org/10.59403/2bsht9a001
Go to Tax Research Platform
Australia: Testing the Tax Treaty Residency Tie-Break Rules for Individuals
DOI: https://doi.org/10.59403/2bsht9a002
Go to Tax Research Platform
France: Concept of Habitual Abode
DOI: https://doi.org/10.59403/2bsht9a003
Go to Tax Research Platform
France: Limited Tax Liability and Residence
DOI: https://doi.org/10.59403/2bsht9a004
Go to Tax Research Platform
Italy: Tiziano Ferro v. Agenzia delle entrate – Language (and Conceptual) Discrepancy?
DOI: https://doi.org/10.59403/2bsht9a005
Go to Tax Research Platform
India: The Dividend Distribution Tax: Entitlement to Treaty Protection?
DOI: https://doi.org/10.59403/2bsht9a006
Go to Tax Research Platform
Denmark: Did an employee’s Home Office constitute a Permanent Establishment? – Article 5 (1) of the Denmark/Germany Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a007
Go to Tax Research Platform
Denmark: Taxation of Income from Independent Personal Services? – Article 14 of the Denmark/China Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a008
Go to Tax Research Platform
France: Concept of the Permanent Establishment
DOI: https://doi.org/10.59403/2bsht9a009
Go to Tax Research Platform
Turkey: Taxation of Digital Advertising Services Income
DOI: https://doi.org/10.59403/2bsht9a010
Go to Tax Research Platform
United Kingdom: Royal Bank of Canada v The Commissioners for Her Majesty’s Revenue and Customs (HMRC)
DOI: https://doi.org/10.59403/2bsht9a011
Go to Tax Research Platform
United Kingdom: Irish Bank Resolution Corporation Ltd v HMRC
DOI: https://doi.org/10.59403/2bsht9a012
Go to Tax Research Platform
Spain: The Limits to the Interpretation of Tax Treaties in light of later Commentaries to the OECD MC: the Spanish Supreme Court Stryker Case
DOI: https://doi.org/10.59403/2bsht9a013
Go to Tax Research Platform
Norway: Associated Enterprises (OECD MC Article 9)
DOI: https://doi.org/10.59403/2bsht9a014
Go to Tax Research Platform
United States: United States Tax Court, The Coca-Cola Company & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent 155 T.C. No. 10
DOI: https://doi.org/10.59403/2bsht9a015
Go to Tax Research Platform
Switzerland: Beneficial Ownership and Dynamic Interpretation of Tax Treaties
DOI: https://doi.org/10.59403/2bsht9a016
Go to Tax Research Platform
Russia: Beneficial Owner/”Actual Owner” and Thin Capitalization
DOI: https://doi.org/10.59403/2bsht9a017
Go to Tax Research Platform
Spain: The Never-Ending Story of Beneficial Owner: The Colgate Case
DOI: https://doi.org/10.59403/2bsht9a018
Go to Tax Research Platform
Germany: Taxation of a severance payment
DOI: https://doi.org/10.59403/2bsht9a019
Go to Tax Research Platform
Switzerland: Distinction between Public and Private Pensions Income under the Swiss and Thailand Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a020
Go to Tax Research Platform
Poland: Withholding tax on the payment of “match sums” to foreign football federations
DOI: https://doi.org/10.59403/2bsht9a021
Go to Tax Research Platform
United States: United States Tax Court, Baturin v. US, 153 T.C. No. 10
DOI: https://doi.org/10.59403/2bsht9a022
Go to Tax Research Platform
Bulgaria: Credit of tax levied not in accordance with the convention – Decision No 409/2020 and of the Supreme Administrative Court
DOI: https://doi.org/10.59403/2bsht9a023
Go to Tax Research Platform
Portugal: Income from Employment and the Burden of Proof
DOI: https://doi.org/10.59403/2bsht9a024
Go to Tax Research Platform
Australia: Facing Its Fears in Respect of the Non-Discrimination Article
DOI: https://doi.org/10.59403/2bsht9a025
Go to Tax Research Platform
Belgium: Increased Attention to Taxpayer Rights in MAPs in Belgian Case Law
DOI: https://doi.org/10.59403/2bsht9a026
Go to Tax Research Platform
Portugal: Discrimination of Permanent Establishments
DOI: https://doi.org/10.59403/2bsht9a027
Go to Tax Research Platform
Brazil: Tax Treaty Issues under the Volvo Case
DOI: https://doi.org/10.59403/2bsht9a028
Go to Tax Research Platform
Germany: Interpretation of the European Arbitration Convention
DOI: https://doi.org/10.59403/2bsht9a029
Go to Tax Research Platform
Canada: Capital Gains on the Sale of Shares – Alta Energy Luxembourg S.A.R.L. v. The Queen
DOI: https://doi.org/10.59403/2bsht9a030
Go to Tax Research Platform
Israel: Prosol Holdings S.A. v. Assessor Tel Aviv 5 49525-02-14
DOI: https://doi.org/10.59403/2bsht9a031
Go to Tax Research Platform
Argentina: Shall the substance over form principle (domestic GAAR) apply to deny treaty benefits arising from Article 22(4) of the OECD MC?
DOI: https://doi.org/10.59403/2bsht9a032
Go to Tax Research Platform
Georg Kofler, Michael Lang, Alexander Rust, Jeffrey Owens, Pasquale Pistone, Josef Schuch, Karoline Spies, Claus Staringer, Alfred Storck, Peter Essers, Eric Kemmeren, Cihat Öner &Daniel Smit.