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Tax impact of European Commission’s draft foreign subsidies Regulation
Under the European Commission’s draft Regulation for a new regime to address the impact of subsidies from non-EU countries on trade within the EU published on 5 May 2021, tax concessions, reliefs and credits granted by the UK or other non-EU countries cou...
Cyber-security in the era of remote working: FCA publishes insights from its 2020 Cyber Coordination Groups
The FCA has published a summary of insights from its 2020 Cyber Co-ordination Groups (CCG) meetings, which aim to help firms share knowledge and discuss good practices in protecting themselves from cyber threats. In 2020 the FCA convened 157 firms in 7 CC...
Europe’s groundbreaking AI Act: are “superfines” the price to pay for trust in tech?
The EU broke new ground on 21 April 2021 by issuing the draft of its proposed harmonised legal framework on AI (the "AI Act"), the first attempt worldwide to specifically regulate this rapidly developing and often misunderstood branch of technology. The p...
The cautionary tale of Mr Bostan Khan
On 30 April 2021 the Court of Appeal handed down its unanimous judgment in Bostan Khan v HMRC. As tax cases go, it is neither the biggest in terms of amounts of tax at stake (except, one assumes, from the perspective of poor Mr Khan) nor the most complex....
Japan and Spain update their double taxation treaty: no withholding on dividends, interest and royalties
Japan and Spain have signed a new tax treaty in connection with income taxes and to prevent tax evasion and avoidance (the “Treaty”). The Treaty introduces major changes to the former treaty, which dated back to 1974, and will result in elimination or red...
Alexa – be secure! New UK cyber laws to protect smart devices
The UK Government has announced “groundbreaking” plans to protect consumers using smart devices from cyber attacks. As sales in smart devices soar (up 49% since the start of the coronavirus pandemic) cyber criminals become more adept at exploiting their s...
German RETT reform finally close to implementation in July 2021
The reform of the German Real Estate Transfer Tax (RETT) Act took a decisive step towards implementation. Since the RETT reform focuses on share transactions relating to all corporations and partnerships owning German real estate, this is relevant for a g...
The long-awaited Euromoney decision has finally appeared. But is it right?
For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test. Both have now resulted in victory for the taxpayer, through the agency of Kevin Prosser QC, and both show yet again the ...
Taxing Tokens
The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad disappointing that HMRC's cryptoassets manual, which it updated recently, still seems in places to use the terms "cryptoasset"...
Taxing Tokens
The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad disappointing that HMRC's cryptoassets manual, which it updated recently, still seems in places to use the terms "cryptoasset"...