Article 13 or Article 10? What if both articles Apply? I recently had an engaging conversation with a …
Article 13 or Article 10? What if both articles Apply? I recently had an engaging conversation with a …
Interpreting the words “incidental to” Facts: The disputed years are 2014 and 2015.
I don’t think so! The key difference lies in the technical explanations of the India-US DTA and Ireland-US …
Liable to tax” – Non-discrimination clause – Irish group relief – USA-Ireland DTA Facts: Two Irish subsidiaries were …
Article 15 of France-UK DTA – Dependent personal services – published on 11 April 2025 Facts: The years …
Can foreign PE be considered as employer under the treaty? Facts: A company incorporated in Germany maintained foreign …
What about foreign losses? The participation exemption was introduced into Irish tax law by the Finance Act 2024.
With Irish group loss relief as core issue Facts: A Dutch parent company held indirectly all the shares …
Article 13(5) or Article 13(6) – India Tribunal Decision Facts: The Appellant is an Irish fund organized as …
Is the interpretation of TAC correct? Facts: The appellant got married in 2020, and the spouse(wife) was a …
