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Digital Services Taxes and the Price of Gross Revenue

September 29, 2026by Dr Dawkins Brown

A 2 or 3 per cent tax on revenue sounds modest until it is set against margin. Digital services taxes are expensive for thin-margin businesses, politically costly for the countries that levy them, and a poor fit for small Caribbean economies. Executive summary A digital services tax (DST) is a tax on the gross revenue...

When Is a Holding Company a Conduit? Understanding Beneficial Ownership and Anti-Avoidance Risk

June 3, 2026by Dr Dawkins Brown

Key Insight: A holding company is not vulnerable merely because it is lean. It becomes vulnerable when it lacks real substance, decision-making autonomy, commercial purpose, and evidence that it controls the income or assets it legally holds. Executive Summary Holding companies remain valuable tools in international tax and corporate structuring. They can support investment management,...

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Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning

June 3, 2026by Dr Dawkins Brown

Executive Summary International tax planning is entering a new era in which paper structures are no longer sufficient, but genuine commercial substance remains powerful. A recent ruling by the First Instance Tax Court of Milan provides an important reminder that foreign holding companies should not automatically be disregarded simply because they are lean, investment-focused...