No tax, no treaty exemption? Italian court denies exemption for untaxed gains
Can a taxpayer rely on a treaty exemption on the disposal of a shareholding if the gain is not taxed in the taxpayer’s state of...
Burlington: taxpayer wins again in treaty purpose test case
In a decision of significance for the secondary debt market, the Court of Appeal in Burlingtonhas unanimously dismissed HMRC’s...
Gunfleet Sands: Supreme Court rules on the limits of “expenditure on the provision of plant”
When is capital expenditure "on the provision of plant” for the purposes of section 11 Capital Allowances Act 2001? This was the question...
Muller – how much of the "real world" should be imported into the notional UK resident company fiction?
There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...
Side-by-side: will acceptance of US minimum taxation standards impact EU competitiveness?
On 5 January 2026, the OECD published the Side-by-Side (SbS) Package. This package complements the OECD Inclusive Framework's model rules...
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