If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

On 30 September 2017, the United Kingdom implemented a powerful new investigative tool known as an “unexplained wealth order” in its Criminal Finances Act 2017. On 7-8 November 2017, London hosted the Fifth OECD Forum on Tax and Crime. Against this background, as well as other recent...

Tax comparatists tend to bemoan the grim status of their chosen field. Complaints are aimed both at the scarcity of decent comparative legal tax scholarship, and at the lack of a theoretical foundation for the study of comparative tax law. The purpose of this Article is to portray a more...

At first sight, the UK’s prominent role in the ‘transformation’ of international tax in recent years is an exemplar of Global Britain at work: using its influence on the world stage to support stronger, more effective international tax cooperation. Arguably it was at the London G20 Summit...

This study was drafted shortly after the announcement of the referendum by which the United Kingdom decided to leave the European Union. In this article, the authors make a comprehensive assessment of what would be the tax consequences attached the decision. The article is of interest not only...

Hybrid entities give rise to international tax problems, and it must be acknowledged, opportunities. Why is this so? This is because, at the heart of the phenomenon, different countries tax systems treat hybrid entities in fundamentally different ways allocating income to different parties. The...

This is the last in a series of four articles, in which the authors compare specific aspects of the real estate investment trust (REIT) regimes in the United States, the United Kingdom and Germany. Previous articles dealt separately with the REIT regimes in each of these countries. The United...

This paper seeks to expose the origins and impacts of electronic commerce on tax revenues, especially with regard to services and intangibles good transferable via download, making an analysis of the international scenario. Therefore, portrays the rise of the internet and its popularization,...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

Individual European country taxes have recently been tailored towards a policy that incentivizes clean energy alternatives in order to curb CO2 and other harmful emissions that contribute to the continent’s carbon footprint. Cutting against this established tax policy, the European Court of...