Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments, including trends influenced by BEPS.
This briefing examines the most important developments in tax treaties over the last three months.
Anson and HMRC
Following the UK Supreme Court decision in Anson v HMRC [2015] UKSC44 HMRC has issued Brief 15 (2015) stating that the decision is specific to the facts found in the case and therefore leaving open the question of whether or not a LLC is to be treated as transparent or opaque for UK tax purposes.
Hybrid entities
Paragraph 6.3 of the OECD art 1 commentary considers the case of a hybrid partnership which is...
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Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments, including trends influenced by BEPS.
This briefing examines the most important developments in tax treaties over the last three months.
Anson and HMRC
Following the UK Supreme Court decision in Anson v HMRC [2015] UKSC44 HMRC has issued Brief 15 (2015) stating that the decision is specific to the facts found in the case and therefore leaving open the question of whether or not a LLC is to be treated as transparent or opaque for UK tax purposes.
Hybrid entities
Paragraph 6.3 of the OECD art 1 commentary considers the case of a hybrid partnership which is...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
important developments in tax treaties over the last three months.
