income tax

Abuse of law, Abuse of rights, Anti-tax avoidance, Beneficial ownership, Canada, Corporate income tax, Direct taxation, Dividends, Double Taxation, income tax, International Tax Law, Loans, OECD MC Convention, Tax Avoidance, Tax haven, Tax Planning, Tax Treaties, United Kingdom, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /Leave a comment

The recent English Court of Appeal decision in Hargreaves Property Holdings Ltd v HMRC [2024] EWCA Civ 365 http://www.bailii.org/ew/cases/EWCA/Civ/2024/365.html  has again examined the meaning of beneficial ownership and the related expression “beneficially entitled” in UK domestic tax law. It follows shortly after the Tax Court of Canada decision in Husky Energy Energy Inc. v The…

Abuse of law, Abuse of rights, Anti-tax avoidance, Beneficial ownership, Canada, Dividends, Double Taxation, Finance, Financial transactions, GAAR, income tax, International Tax Law, Luxembourg, MLI, OECD, OECD MC Convention, Share Dealings, Tax Avoidance, Tax haven, Tax Treaties, Treaty shopping, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /Leave a comment

In my previous blog I examined the Tax Court of Canada’s analysis of the meaning of beneficial ownership in tax treaties in Husky Energy Inc. v The King, 2023 TCC 167 in relation to stock or securities lending. This post examines the application of the General Anti-Avoidance Rule(GAAR) in Canada to the transactions. The facts…

Argentina, income tax

(Bomchil)/ /1 Comment

Main features of the new extraordinary prepayment on account of Income Tax  General Resolution 5248/22 (the Resolution), issued by the Argentine Tax Agency (AFIP), and gazetted on August 16, 2022, set forth an extraordinary (“one-time”) prepayment on account of Income Tax payable by corporate taxpayers contemplated in article 73 of the Income Tax law (ITL)[i]….