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Stop the press! Taxpayer wins Ramsay appeal on disclosed avoidance scheme
"We understand that some readers of this decision may find it surprising that an artificial series of transactions which, on the unchallenged findings of the FTT, were devoid of business purpose and effected only to achieve a "magical" increase in qualify...
Has the ICO just told lawyers not to advise clients to pay ransoms?
Ransomware attacks are on the rise, and more organisations have been paying the ransoms in recent months. In light of this, the ICO and National Cyber Security Centre (‘NCSC)’ have published a joint letter they sent to the Law Society regarding ransomware...
Restrictive immunity: codifying the UK's approach to taxing sovereign investors
The doctrine of sovereign immunity is the international law principle that one sovereign State should not seek to apply its law to another sovereign State. In the UK, the application of that principle to the courts is governed by the State Immunity Act 19...
Rise of the machines? As the UKIPO publishes the results of its consultation on AI and IP, are we about to enter a new dawn?
The UKIPO has published its response to its consultation on AI and IP. Whilst the Government has decided not to make any changes to existing protection for computer-generated works or to UK patent legislation in respect of AI-devised inventions, it has de...
IP in the Metaverse
Ever since Facebook rebranded as “Meta”, everyone has been talking about the Metaverse. But what exactly is it (or could it be) and what does it mean for intellectual property rights? We give a few initial thoughts below. The Metaverse As things currently...
Key takeaways from the ClimateTech Summit (part of London Tech Week)
During the hectic schedule of London Tech Week - the flagship annual tech event in the UK – we were lucky enough to attend the thought-provoking ClimateTech Summit on the second day of the conference. At the intersection of both our Sustainability and Tec...
Greening Imports: UK Government to consult on a unilateral CBAM
It's been an interesting month so far in the world of climate taxes. For a brief moment it looked as though pens were down on the European Carbon Border Adjustment Mechanism (CBAM), Social Climate Fund and Greenhouse Gas trading proposals, pending politi...
German foreign-to-foreign IP taxation: Ministry listens to complaints and prepares for an end
On 16 June 2022, the German Federal Ministry of Finance (MoF) submitted to the finance committee of the German parliament its evaluation report of the “register cases” reported since 2020. “Register cases” are instances where, on the MoF’s interpretation ...
What we can expect in the Data Reform Bill: UK Government publishes consultation response on UK data protection law reform
The UK government has published its response to the 2021 Data: a new direction consultation (which we discussed in our September blog), outlining which of the consultation’s proposals will be included in the forthcoming Data Reform Bill. Some of the more ...
The 'super-deduction': unobtainable by design?
The draft Energy (Oil and Gas) Profits Levy Bill published on 21 June 2022 (the Bill) shows the difficulty, and danger, of using purpose tests in legislation when the Government is seeking to use tax to influence behaviour. It can have the effect of rende...