Allocation issues: Transfer pricing and tax avoidance: just and reasonable solutions?
Article by Jonathan Schwarz (first published on KluwerTaxBlog) When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury.…
Category: United Kingdom
Income from immoveable property: Article 6 and royalty streams
Article by: Jonathan Schwarz, first published on KluwerTaxBlog Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has…
The relationship between treaties and domestic anti-abuse provisions
Article by: Jonathan Schwarz (Temple Tax Chambers; King’s College London) – First published on KluwerTaxBlog In last month’s blog I promised to address the treaty…
The eye of the needle: Is one of your purposes tax avoidance?
Article by Jonathan Schwarz, first published on http://kluwertaxblog.com/. We have all become familiar with the expression in the PPT set out in article 7(1) of…
Deeming Fictions in the Context of Tax Treaties – Highlights of and Comments on Arguments in HMRC v. Fowler
By: Dhruv Sanghavi The Supreme Court of the United Kingdom heard the case of HMRC v. Fowler on Tuesday 24 March 2020. This was only…
