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HMRC’s “known position” on transfer pricing compliance HMRC’s Transfer Pricing Guidelines for Compliance (GfC7) are promoted as “best practice approaches to transfer pricing to lower risk and avoid common mistakes”. This may sound like helpful “take it or leave it” guidance, but it should be noted that the gu... AT&T v Broadcom VMware – are you ready for renewal? In the latest move in an interesting (and now very public) dispute, Broadcom has responded to AT&T’s claim against it in the New York courts.   AT&T, the Fortune 500 telco giant, has a perpetual licence of VMware virtualisation software. It is seeking a m... The ICO’s cookie focus is extending to ad tech: 5 things you need to know The ICO has confirmed a continuation and extension of its work to tackle cookie compliance. In a statement issued last week, the regulator stated it had taken regulatory action following a nearly two-year long investigation into the cookie practices of Sk... European Commission publishes Competition Policy Brief on generative AI and virtual worlds On 19 September 2024, the European Commission published a Policy Brief on competition in generative AI and virtual worlds.  The Policy Brief explores emerging market trends and perceived risks to competition in these sectors.  It also examines the tools i... Cyber optics: ICO and NCA sign collaborative memorandum to improve the UK’s cyber resilience On 10 September 2024, the ICO announced it had signed a memorandum of understanding with the National Crime Agency (“NCA”). The joint statement of intent sets out how the regulators will cooperate and work constructively with one another in relation to th... Designating UK Data Centres as Critical National Infrastructure: A New Era of Growth and Security? We shared some views back in December 2023 around the UK government’s consultation on proposed regulations to improve the security and resilience of UK data infrastructure, part of which involved consideration as to whether to designate elements of the da... Who’s who in the genAI supply chain: ICO publishes draft guidance on controllership In its fifth and final call for evidence on the topic of generative AI (genAI), the ICO has chosen to tackle a complex, but important, topic: controllership. In many ways, this is a crucial first step – without clarity on who is controller, processor or w... The EU Data Act - one year to go: what you need to know to prepare Whether you want to explore different aftercare services for the IoT products you use, switch your cloud service provider, or agree reasonable terms around your data sharing arrangements, now is the time to consider whether the EU Data Act could help. Wit... How does the purpose of your borrowing impact tax deductibility? It will come as no surprise that the UK imposes certain restrictions on companies’ ability to deduct interest when calculating the profits that are subject corporation tax.  One of these restrictions is the unallowable purpose rule in section 441 of the C... Things get Emotional as Court of Appeal says ANN inventions do engage computer program exclusion We have previously discussed (here, here and here) the exclusion of computer programs from UK patentability and its significance to the patentability of AI inventions. Although it seemed that the High Court in Emotional Perception AI Ltd v Comptroller Gen...