No man is an island

AS AN ISLAND race it is probably all too easy to believe that events abroad impact upon us in a minimal way if at all. And perhaps this is a trap that tax practitioners especially those who feel that international tax affairs are of limited relevance to their clients may also succumb to. Although it concerned a German national and although he lost a recent case before the European Court of Justice (ECJ) shows that European Community rights under the EC Treaty are more pervasive than previously realised. Had the taxpayer won double taxation treaties might have become available on a 'pick 'n' mix' basis to clients with foreign income and possessions; and bearing in mind that the opinion of the Advocate-General was in the taxpayer's favour one wonders if a stronger case would have resulted in the 'upheaval' that he foresaw.