Tax Treaty Case Law around the Globe 2021

Type Book

Series

TTCL Series

Editor(s)

Georg Kofler et al.

Date of publication

September 2022

DOI https://doi.org/10.59403/2bsht9a

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Tax Treaty Case Law around the Globe 2021

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.

This book is part of the Tax Treaty Case Law around the Globe Series

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Sample excerpt, including table of contents

Editor(s)

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.
















Tax Treaty Case Law around the Globe 2021: https://doi.org/10.59403/2bsht9a
Austria: Supreme Administrative Court on a Hybrid “Sandwich Structure”: https://doi.org/10.59403/2bsht9a001
Australia: Testing the Tax Treaty Residency Tie-Break Rules for Individuals: https://doi.org/10.59403/2bsht9a002
France: Concept of Habitual Abode: https://doi.org/10.59403/2bsht9a003
France: Limited Tax Liability and Residence: https://doi.org/10.59403/2bsht9a004
Italy: Tiziano Ferro v. Agenzia delle entrate – Language (and Conceptual) Discrepancy?: https://doi.org/10.59403/2bsht9a005
India: The Dividend Distribution Tax: Entitlement to Treaty Protection?: https://doi.org/10.59403/2bsht9a006
Denmark: Did an employee’s Home Office constitute a Permanent Establishment? – Article 5 (1) of the Denmark/Germany Tax Treaty: https://doi.org/10.59403/2bsht9a007
Denmark: Taxation of Income from Independent Personal Services? – Article 14 of the Denmark/China Tax Treaty: https://doi.org/10.59403/2bsht9a008
France: Concept of the Permanent Establishment: https://doi.org/10.59403/2bsht9a009
Turkey: Taxation of Digital Advertising Services Income: https://doi.org/10.59403/2bsht9a010
United Kingdom: Royal Bank of Canada v The Commissioners for Her Majesty’s Revenue and Customs (HMRC): https://doi.org/10.59403/2bsht9a011
United Kingdom: Irish Bank Resolution Corporation Ltd v HMRC: https://doi.org/10.59403/2bsht9a012
Spain: The Limits to the Interpretation of Tax Treaties in light of later Commentaries to the OECD MC: the Spanish Supreme Court Stryker Case: https://doi.org/10.59403/2bsht9a013
Norway: Associated Enterprises (OECD MC Article 9): https://doi.org/10.59403/2bsht9a014
United States: United States Tax Court, The Coca-Cola Company & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent 155 T.C. No. 10: https://doi.org/10.59403/2bsht9a015
Switzerland: Beneficial Ownership and Dynamic Interpretation of Tax Treaties: https://doi.org/10.59403/2bsht9a016
Russia: Beneficial Owner/”Actual Owner” and Thin Capitalization: https://doi.org/10.59403/2bsht9a017
Spain: The Never-Ending Story of Beneficial Owner: The Colgate Case: https://doi.org/10.59403/2bsht9a018
Germany: Taxation of a severance payment: https://doi.org/10.59403/2bsht9a019
Switzerland: Distinction between Public and Private Pensions Income under the Swiss and Thailand Tax Treaty: https://doi.org/10.59403/2bsht9a020
Poland: Withholding tax on the payment of “match sums” to foreign football federations: https://doi.org/10.59403/2bsht9a021
United States: United States Tax Court, Baturin v. US, 153 T.C. No. 10: https://doi.org/10.59403/2bsht9a022
Bulgaria: Credit of tax levied not in accordance with the convention – Decision No 409/2020 and of the Supreme Administrative Court: https://doi.org/10.59403/2bsht9a023
Portugal: Income from Employment and the Burden of Proof: https://doi.org/10.59403/2bsht9a024
Australia: Facing Its Fears in Respect of the Non-Discrimination Article: https://doi.org/10.59403/2bsht9a025
Belgium: Increased Attention to Taxpayer Rights in MAPs in Belgian Case Law: https://doi.org/10.59403/2bsht9a026
Portugal: Discrimination of Permanent Establishments: https://doi.org/10.59403/2bsht9a027
Brazil: Tax Treaty Issues under the Volvo Case: https://doi.org/10.59403/2bsht9a028
Germany: Interpretation of the European Arbitration Convention: https://doi.org/10.59403/2bsht9a029
Canada: Capital Gains on the Sale of Shares – Alta Energy Luxembourg S.A.R.L. v. The Queen: https://doi.org/10.59403/2bsht9a030
Israel: Prosol Holdings S.A. v. Assessor Tel Aviv 5 49525-02-14: https://doi.org/10.59403/2bsht9a031
Argentina: Shall the substance over form principle (domestic GAAR) apply to deny treaty benefits arising from Article 22(4) of the OECD MC?: https://doi.org/10.59403/2bsht9a032