Introductory materials on international tax

[This page is still a work in progress]

This is intended to be a repository of introductory materials on international tax law.

Multilateral efforts:

Domestic Materials: Reports

Cases: Interpretation of tax treaties

Cases: Permanent Establishments / Attribution

Cases: Fiscally transparent entities

“Source”

Non-Indian cases

Here are some interesting judgments (sorted chronologically, not by jurisdiction) across the common law world, illustrating what is meant by “source of income”:

In general, the principle in Nathan has been followed: however, ultimately, it is necessary to look at the language in each relevant enactment before applying these cases as a general rule.

In some of these categories, this page is only intended to collate various links for ease of access. In other categories (particularly those involving case-law), I have presently provided links to freely available text of the cases. I will in due course add case-notes on some of the cases.

These materials are not an exhaustive introduction (indeed, they are nowhere close to being exhaustive); and the page is will be updated regularly. In case readers think that any specific materials should be added on here, let me know using the contact feature.