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Journal Article
Treaty Interpretation and Treaty Override: The Spanish Case Law on Royalties under the Spain-United States Income Tax Treaty (1990)
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Journal Article
A Modern Understanding of Article 31(3)(c) of the Vienna Convention (1969): A New Haunt for the Commentaries to the OECD Model?
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Journal Article
Treaty Override – Revival of the Debate over the Constitutionality of Domestic Treaty Override Provisions in Germany
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Journal Article
Can, and Should, the Parol Evidence Rule Be Invoked by or against the Canadian Tax Authorities in Tax Litigation? Lessons from US Jurisprudence
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Journal Article
TP or Not TP: Examining the Applicability of the Arm’s Length Principle to Inter-Company Equity Financing Transactions
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Journal Article
Permanent Establishment Implications for Coordination Centres in the Oil and Gas Industry
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