English may be the lingua franca of our time, but it is not the only language of international law. Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC). raised issues around the interpretation of a tax treaty concluded in English and French, both languages being equally authentic. The complex facts are summarised at https://kluwertaxblog.com/2020/07/29/income-from-immoveable-property-article-6-and-royalty-streams/….
When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place…
The present article explores some concrete application cases of Big Data in Tax Administrations (TAs). It then formulates some ideas for its possible expansion in the near future, considering both advantages and disadvantages. 1. Big Data The concepts of Big Data, data analytics and artificial intelligence are not new. Still, some technological advances have made…
