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New limitation on the offsetting of tax losses generated in 2023 by entities taxed under the Spanish CIT consolidation regime This post provides an overview of the Spanish legal framework applicable to the use of carried forward tax losses (NOLs) and briefly analyses the temporary limitation introduced by the recently published Law 38/2022, of 27 December, regarding the use of t... To borrow or not to borrow: key considerations for “venture debt” deals If you are a tech start-up, or your organisation invests in or helps develop them, you will have seen market speculation that 2023 is likely to be a difficult year for tech businesses to raise venture capital. At the end of last year, we set out some key ... ICAAPS, ILAAPS, recovery plans and now, carbon transition plans? Under the draft Capital Requirements Directive VI (the Draft), European credit institutions will be required to prepare and update annually ‘carbon transition plans’. Although the Draft mandates the European Banking Authority (EBA) to flesh out their cont... Share deals in peril of double taxation under new RETT law The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares in an entity holding real estate located in Germany. Pursuant to this theory, the conclusion of the agreement (signing)... CJEU says Amazon may be liable for trade mark infringement for sale of counterfeit Louboutins The Court of Justice of the European Union (“CJEU”) has held that online sales websites like Amazon that operate a “hybrid” business model (offering both the operator’s own sales as well as a marketplace for third parties) may be liable for trade mark inf... ICO tech report highlights privacy challenges for four key technologies The ICO is encouraging developers to consider privacy at an early stage when implementing new technologies and, in its first annual Technology horizons report, examines the implications of some of the most significant technological developments for privac... International tax reform – now more worth the effort? At a webinar on 18 January, the OECD presented its findings on the impact of international tax reform in advance of the full report which will follow in the coming months. International tax reform is politically and technically complex, but the OECD’s lat... New app store Code of Practice In December last year, the Department for Digital, Culture, Media and Sport (DCMS) published a new ‘first of its kind’ code of practice aimed at protecting app users. While the code is voluntary, the Government is expecting app store operators and app dev... Accountability and technology: imagining the future of the SM&CR The Senior Managers and Certification Regime or 'SM&CR', a regulatory lever which seeks to foster greater individual accountability within (most) regulated firms, and which takes aim at the conduct failings that fuelled the 2008 banking crisis, is set to ... HMT Review of Payment Services Regulations: is this the beginning of a tectonic shift in the regulatory bedrock? Ten years ago, the thought of your phone scanning your face before you pay for your morning coffee may have been a disturbing one. Five years ago, sharing your account information with anyone but your bank would have been unthinkable. And a year ago, for ...