Dividends and Interest
Session 4: 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, 16:15-17:55
All time slots are Central European Time (CET).
Location:
- Tilburg University, Dante Building, Room DZ 2, Warandelaan 2, 5037 AB, Tilburg or
- Online
Chairs
Content
Denmark
| Speaker | Location |
| Søren Friis Hansen | On Campus |
Whether the subsidiaries were in fact, the ‘Beneficial Owners’ of the distributed dividends
- The Eastern High Court, 3 May 2021
- Case No: SKM2021.304ØLR
France
| Speaker | Location |
|
|
On Campus |
Interpretation of the conventional terms “profits”, “income,” and “other positive income” and imputation of tax credits
- French Supreme Court (Conseil d'Etat) 8e et 3e ch. HSBC Bank Plc Paris Branch, 11 May 2021
- Case No: n°403692
India
| Speaker | Location |
| D.P. Sengupta | Online |
Interpretation of the MFN clause in respect of passive income found in some of India’s treaties with the OECD Member countries
- Concentrix Services Netherlands BV v Income Tax Officer - Delhi High Court, 22 April 2021
- Case No: WP (C) 9051/2020
Luxemburg
| Speaker | Location |
| Werner Haslehner | On Campus |
The qualificxation of cross-border interest between a tax transparent partnersip and its partner
- Trib. Admin., 28 October 2021
- Case No: 41517
Portugal
| Speaker | Location |
| Ana Paula Dourado | Online |
A domestic exemption applies to investment income (interest, dividends), rental income and capital gains, provided that such income is taxable in the source country
- Decisão Arbitral do CAAD, 12 May 2021
- Case No: 401/2020-T