The paper provides a number of comments on the Platform on Collaboration on Tax (PCT)'s draft Toolkit on Tax Treaty Negotiations. This submission is comprised of two parts. The first part discusses the terminology currently being employed in the PCT Toolkit on Tax Treaty negotiation, and...

The paper provides comments in response to the UN Tax Commitee's call for public comments on Tax Committee’s draft agenda for the membership for the session of 2021-2025. Four topics are presented which should be considered by the UN Tax Commitee. These items are:1. Source taxation of...

In this article, the author considers the implications of the recent decision of the French Conseil d’État (Supreme Administrative Court) regarding the recognition of a hidden agency permanent establishment that was used by the Irish company to sell online advertising services in France,...

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state – the state where the shipowners are...