Rule of law

Corporate income tax, Double Taxation, Finance, Financial institutions, Financial services, International Tax Law, Liability to tax, MLI, OECD, Permanent Establishments, POEM, Residence, Rule of law, Tax Treaties, United Kingdom, United Nations, United States

(Temple Tax Chambers; King’s College London)/ /1 Comment

G E Financial Investments Limited v HMRC [2021] UKFTT 210 (TC)  raised central aspects of the interpretation of double tax treaties. My previous blogs considered the corporate residence  under article 4(1) of the UK-US Double Tax Treaty and the existence of a permanent establishment under article 5(1) of the treaty. The First-tier Tribunal decided that…

European Commission, Hungary, Poland, Rule of law

(Universiteit van Amsterdam)/ /3 Comments

For some time now, Poland and Hungary have been under scrutiny from the European Commission for their violation of the rule of law, as we read with some regularity in the daily press. Recently, Poland was even fined by the European Commission. One of the defenses of these Member States is that the EU itself…