Tax Treaty Case Law around the Globe

Interpretation and Residence

Session 1: Tax treat case law around the globe 2022

In each session of the hybrid conference, tax treaty cases will be presented and subsequently analyzed in a critical discussion. This discussion includes the possible impact of the cases on the interpretation and application of tax treaties in other countries. Participants are invited to join the discussions actively. The scientific results of the conference will be published in a book by the IBFD. 

Date and time

  • Friday, May 13, 2022, 09:30 – 10:50      
    All time slots are Central European Time (CET).


  • Tilburg University, Dante Building, Room DZ 2, Warandelaan 2, 5037 AB, Tilburg or
  • Online



The Netherlands

Speaker Location
Ton Stevens On Campus

The definition of international traffic in Art.3(1)(g) of the DTT

  • Supreme Court (Hoge Raad), 24 December 2021
  • Case No(s): 20/03226, 20/03227, 20/03228


Speaker Location
Luís Eduardo Schoueri Online

Center of vital interests set in article 4(2)(a)

  • Administrative Council of Tax Appeals (“CARF”) - Voluntary Appeal - Tarcisio Montagna vs. Federal Union, 12 May 2021
  • Case No: 10380.003494/2009-57


Speaker Location
David Duff On Campus

Interpretation of tie-breaker rule for dual resident entities in Article 4(3) of the Canada-Netherlands DTT

  • Tax Court of Canada, 8 March 2022
  • Case No: Landbouwbedrijf Backx BV (TCC, 2021)


Speaker Location
Ana Paula Dourado Online

Trust submitted a declaration to the Canadian Tax Authorities stating that it is a tax resident in Canada

  • Judgment of the South Central Administrative Court, 17 October 2021
  • Case No: Ac. TCAS, 42/10.8BELRS