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Wednesday, April 24, 2024

Jason Chen

BO Bites Husky, GAAR Remains Toothless – Part II. The (Toxic) Relationship of BO and GAAR in Light of the Husky Energy case

Part II. The (Toxic) Relationship of BO and GAAR in Light of the Husky Energy case. “[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be taxed on the income. [(…)] The concept of beneficial ownership is not a good anti-avoidance rule...

BO Bites Husky, GAAR Remains Toothless – Part I. International treaty autonomous BO-GAAR relationship

Part I. International treaty autonomous BO-GAAR relationship “[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be taxed on the income. [(…)] The concept of beneficial ownership is not a good anti-avoidance rule for dealing with conduit and other tax avoidance arrangements....

BO Bites Husky, GAAR Remains Toothless – Part I. International treaty autonomous BO-GAAR relationship

Part I. International treaty autonomous BO-GAAR relationship “[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be taxed on the income. [(…)] The concept of beneficial ownership is not a good anti-avoidance rule for dealing with conduit and other tax avoidance arrangements....

The Contents of EC Tax Review, Volume 33, Issue 02, 2024

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Bruno Peeters, European Law Restrictions on Tax Authorities’ Use of Artificial Intelligence Systems: Reflections on Some Recent Developments The article discusses the increasing use of artificial intelligence (AI) by tax authorities in the...

The Contents of Highlights & Insights on European Taxation, Issue 3, 2024

Highlights & Insights on European Taxation Please find below a selection of articles published this month (March 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation...

The Contents of Highlights & Insights on European Taxation

Highlights & Insights on European Taxation Please find below a selection of articles published this month (February 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the...

The UN Proposal on Revision of Article 8 – Focus Airlines: Critical analysis and our take on whether it is in the Interest of...

What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention between Developed and Developing Countries (“UN Model 2021”)[1] offers two alternatives under Article 8. Alternative A aligns with the OECD Model Tax Convention on Income and...

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