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Tax residence post-MLI
Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD) residence tie-breakers have been removed from some of the UK's tax treaties in favour of competent authority determinati...
Can Corporate PPAs help facilitate the "Green Recovery"?
Corporate Power Purchase Agreements (CPPAs) could have great potential to enable a "green recovery". We discuss what corporates should consider before entering a CPPA.
As lockdown eases and the UK emerges from the most damaging effects of the C...
Insurance Newsletter - July 2020
This newsletter highlights selected legal and regulatory developments in insurance.
In this newsletter:
The future of insurance regulation post-Brexit
Green recovery and the insurance sector
The impact of COVID-19 on insurer solvency
Back to the future
When I first qualified into tax, UK-UK transfer pricing was not a thing. A UK company could lend money to a fellow UK group company without being required to impute interest on the loan. A UK parent could guarantee the loan of its UK subsidiar...
EFIG: European Banking Newsletter - July 2020
Developments covered in this month’s edition include:
ECB publishes its Monetary Policy Decisions
Single Supervisory Mechanism - ECB publishes report on credit underwriting standards
The future of European banking regulation in the aftermath of...
The ECB eligibility criteria and asset purchase programmes after the Brexit implementation period
In response to the COVID-19 pandemic, central banks across the world set out a range of monetary stimulus packages. One such scheme is the European Central Bank’s Pandemic Emergency Purchase Programme (“PEPP”), aimed at supporting Eurozo...
Limited Partnership Fund Ordinance: A new fund vehicle for private equity in Hong Kong
The Limited Partnership Fund Ordinance (Cap. 637) provides a new fund vehicle for private equity in Hong Kong and will take effect on 31 August 2020.
On 17 July 2020, the Limited Partnership Fund Ordinance (Cap. 637) (LPFO) was gazetted, marking the lat...
A simpler and more modern tax environment sounds good – but what about tax competition?
The Apple case is seen as raising the (very) hot topic of how a multinational group like Apple should be taxed in a modern, digital world. In a briefing on our website, Mike Lane and Isabel Taylor review the case and consider the implications of the decis...
Employment Bulletin - July 2020
Topics covered in this bulletin:
Worker with open-ended contract was an agency worker
Employer’s approach to alternative employment on redundancy was unfair
Refusal to give an undertaking was a failure to make reasonable adjustments
European C...
Apple v Commission: the verdict’s in
Mike Lane and Isabel Taylor review the decision of the General Court of the European Union in Apple Sales International (ASI) and Apple Operations Europe (AOE) v Commission.
The victory for Apple and Ireland in their €13bn State aid dispute ...