Tax Treaty Case Law around the Globe

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).


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




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


Speaker Location

Marilyne Sadowsky


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


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


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


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