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Situated at the crossroad of Europe, the Grand-Duchy of Luxembourg is based on a dynamic and open economy which actively promotes the development of cross border trade and investments.
The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of...
The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta…
The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held...
Data and research on tax treaties including OECD Model Tax Convention, Mutual Agreement Procedure Statistics, prevention of treaty abuse., The MLI has already started to impact the bilateral treaties of 68 jurisdictions that have ratified it. From 1 January 2022, it is expected to impact over 850 treaties concluded among those 68 jurisdictions, with an additional 900 treaties whose application would be modified once the MLI is ratified by all Signatories, thereby affecting a total of 1750 treaties worldwide.