Supreme Court

Abuse of rights, Administrative Co-operation, Brexit, Double Taxation, EU law, EU/EEA, International Tax Law, Tax Treaties, United Kingdom

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

The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good faith. The Agreement does not seek to replicate many of the rights which UK citizens and businesses had under EU law. There is no general non-discrimination provision. Double…

Double Taxation, India, International Tax Law, OECD, Tax Treaties, Withholding Taxes

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

Those with a long memory for cricketing events may remember the 1996 World Cup hosted jointly by India, Pakistan and Sri Lanka. The winner, Sri Lanka, made 398 runs for 5 wickets, in a one-day international match, a record that stood until April 2006. South Africa’s Gary Kirsten scored 188 runs, not out, against the…

BEPS, Hybrids, OECD, Tax Treaties

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

This week, the United Kingdom Supreme Court, in a landmark decision, has ruled that a UK resident individual member of a Delaware limited liability company is entitled to credit in the UK for US tax on the profits of the LLC. Anson v Commissioners for Her Majesty’s Revenue and Customs [2015] UKSC 44 has rejected…