Tax Treaty Case Law around the Globe


Session 5: 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

  • Saturday, May 14, 2022,  09:00-10:20
    All time slots are Central European Time (CET).


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




Speaker Location
Luís Eduardo Schoueri Online

The assessment on wheather the payments could qualify either as "royalties" or income from "independent professional services"

  • Federal Regional Court of the 4th Region (TRF4) –WEG Equipamentos Elétricos S/A., WEG Tintas Ltda. and WEG Drives & Controls - Automação Ltda.  vs. Federal Union, 09 June 2021
  • Case No: Appel no. 50000547-48.2016.4.04.7209 -


Speaker Location

Marilyne Sadowsky

On Campus

Quallification of remunerations paid in the context of software licensing and maintenance services and interpretation of articles on royalties or eleimination of double taxation of serveral bilateral tax treaties.

  • Sté Sopra Steria Group CE 9e et 10e ch., 18 June 2021
  • Case No(s) n°433315 / 433319 / 433323


Speaker Location
Esteban Montenegro Online

The application of Art. 12 on royalties of the DTT between Peru and Chile - beneficiary owner issues

  • Peruvian Tax Court, date 21 July 2020 (made public in October 2021)
  • Case No: Ruling N° 03306-9-2020  


Speaker Location
Karolina Tetlak Online

Recognition of a foreign organization associating artists and selling copyrights of their works as the actual benficiary of the receivables

  • Supreme Administrative Court, 12 August 2021
  • Case No: II FSK 126/19