Can you give examples where domestic tax rules override the UN and OECD Model Treaties?
In this Q&A session, we explore the interaction between domestic tax rules and the provisions of the UN and OECD Model Tax Treaties. While these treat…
Tag: Tax Avoidance
X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
Apple Loses €13 Billion Tax Battle: Quick Take
The final ruling by the European Court of Justice (ECJ) in the Apple-Ireland tax case is a significant moment in the ongoing efforts to address profit…
Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s…
Lexel AB v Sweden (Skatteverket): CJEU Ruling on Interest Deductions and Freedom of Establishment
In Lexel AB v Skatteverket (Case C‑484/19), the Court of Justice of the European Union (CJEU) ruled that Swedish tax legislation, which denied Lexel…
Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance
The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States'…