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On August 22, 2024, Germany’s Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation, particularly for Luxembourg-based funds investing in Germany....more
Background - In GE Financial Investments Limited the Court of Appeal (“CoA”) overturned the Upper Tribunal’s (“UT”) decision and held that double taxation relief was not available under the UK-US double tax treaty (the...more
Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more
The U.S. Department of the Treasury on June 17, 2024, confirmed it had formally notified Russia about the suspension of the Convention between the United States of America and the Russian Federation for the Avoidance of...more
El CDI con Reino Unido no activó cláusula de nación más favorecida de los CDI con España, Suiza y Chile para servicios técnicos, de asistencia técnica y consultoría En Sentencia con Radicado 25411 del 4 de abril de 2024,...more
This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
On Oct. 25, the Chilean government submitted the reservations made by the U.S. Senate regarding the U.S.-Chile bilateral income tax treaty (the Tax Treaty) to the Chilean Congress for approval. Chilean tax practitioners...more
In many respects, the Upper Tribunal’s decision in Hargreaves Property will not have surprised tax practitioners as the decision reaffirms best practice considerations around a number of fundamental concepts in relation to...more
The identification of where a company is resident is a critical element in accessing the benefits of a double tax treaty. GE Financial Investments Limited (“GEFI Limited”) was a UK incorporated and tax resident company...more
On 19 July 2023, the new convention for the elimination of double taxation (the “New Convention”) between Luxembourg and the United Kingdom (the “Contracting States”) and its protocol were ratified by the Luxembourg Chamber...more
The U.S. Senate, in a vote of 95-2 on June 22, 2023, approved a Resolution of Advice and Consent (the Resolution) to ratify the Convention Between the Government of the United States of America and the Government of the...more
On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more
Short Summary: The case discusses the validity of a closing agreement and if a taxpayer can set aside such agreement under malfeasance or misrepresentation of fact....more
The UK’s First-tier Tribunal recently held that the payment of interest received by Burlington Loan Management DAC (“BLM”) (an Irish tax resident company) was not to be denied the benefits of the relief afforded under the...more
Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD)...more
More than four yeas after the announcement of negotiations, the new tax treaty between Luxembourg and the United Kingdom was finally signed on 7 June 2022, together with a Protocol adding further detail. ...more
The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more
Since April 2020, the Russian Federation has been taking actions to increase tax rates for several types of income under double taxation treaties (DTTs) with jurisdictions that the Russian government recognizes as mainly used...more
On Monday, 31 May 2021, the UAE and Israel signed a tax treaty in order to boost economic cooperation. It is expected that, following ratification later this year, the treaty will come into effect on 1 January 2022. The move...more
On 6 November 2020, Luxembourg and Russia signed a Protocol amending the Luxembourg-Russian Double Tax Treaty. This new Protocol provides new withholding tax rates and rules for the taxation of dividends and interest...more
On 11 March 2021, the Luxembourg Tax Authorities published a Circular providing guidance on the process for initiating the mutual agreement procedure (“MAP”) under bilateral income tax treaties and explaining the interaction...more
Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more