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Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation, [2024] FCAFC 29-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 an independent enterprise would have agreed to allow interest to be capitalized, but not to make it contingent on cash flow The taxpayer (“STAI”)- a wholly-owned Australian subsidiary of a Singapore public company (Singapore Telecommunications Limited, or “SingTel”)- purchased in June 2002 all the shares of an Australian telecommunications company (“SOPL”) from another wholly-owned subsidiary of SingTel (“SAI”), which was accepted to be a Singapore enterprise. ...

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose BLM was a substantial Irish-resident investment company, which started acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) in 2011 and came to own 443 such claims. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 695, aff'd [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty is not income from immovable property under the Canada-U.K. ...

Royal Bank of Canada v Commissioners for His Majesty's Revenue and Customs, [2025] UKSC 2-- summary under Article 6 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 6 an oil and gas royalty was too remote from a land interest in the oil field to be immovable property under the Canada-U.K. ...