In my last blog, I looked at the immediate impact of Covid 19 Lockdowns on key elements of double tax treaties – residence, permanent establishment and employment income. Many tax administrations have published guidance on their approach to these issues. Indeed, almost immediately after the OECD also published helpful comment on them too. The general…

By now, warranty & indemnity (W&I) insurance is more or less a transaction solution commodity. As such, it clearly has entered its next product life-cycle phase. Expectations are that stand-alone tax insurance will quickly follow suit.   As W&I insurance has grown in popularity, tax insurance has been most often used as an add-on to W&I insurance to provide…