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The Spanish Supreme Court stands as the latest pacta sunt servanda watch The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the recipient of the royalties was not their beneficial owner because the relevant article did not include a beneficial owne... Argentina: new reporting regime for domestic and international tax planning arrangements The Argentine Tax Authority (AFIP) published a broadly drafted mandatory reporting regime for domestic and international tax planning arrangements in the Official Gazette on 20 October 2020. The Resolution became effective on the same day, but may require... Virtual currencies: what's in a name? Spend too long thinking about the virtual or digital world in opposition to the "real" world, and it's almost guaranteed you'll start overthinking concepts we take for granted on a daily basis. Take money, for example.  According to the OECD's recent repo... Timed out? On-shoring the EU’s COVID capital markets quick fixes Irrespective of COVID, the Brexit clock continues to tick down to 31 December 2020, the day the implementation period ends. On IP completion day, under the European Union (Withdrawal) Act 2018, the body of EU law then applicable will be converted into UK ... Export control, trade wars and Brexit Brexit and the US-China trade war are generating significant new developments in the historically quite slow-moving area of export control law.  Businesses operating internationally, particularly in the technology sector, are facing new compliance challen... Export control, trade wars and Brexit Brexit and the US-China trade war are generating significant new developments in the historically quite slow-moving area of export control law.  Businesses operating internationally, particularly in the technology sector, are facing new compliance challen... Is London Calling (again) for the EU Copyright Directive? The EU Copyright Directive had appeared to be casualty of Brexit, but might now get a second wind.  As Mayor of London, Boris Johnson was once asked how he listens to music, “Have you discovered this wonderful thing called YouTube? I am afraid I just dial... European Commission initiates review of VAT rules for financial and insurance services On 22 October 2020, the European Commission published an inception impact assessment for the review of the VAT rules for financial and insurance services, as announced earlier this year in the Action Plan for Fair and Simple Taxation Supporting the Recove... Spain introduces Financial Transaction Tax The Financial Transaction Tax was approved on 7 October 2020, allowing Spain to tax the acquisition of listed shares issued by Spanish companies, following the trend initiated by other countries, such as France and Italy. The Spanish FTT will be charged a... Can administrative guidelines fix a legal provision which is inconsistent with EU principles? The French Administrative Supreme Court has recently ruled, in the context of the capital gains tax charge applicable to non-residents on the transfer of a significant shareholding, that the administrative guidelines cannot be used to fix a legal provisio...