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'Technology, Access to Justice and the Rule of Law': a new report from the Law Society Despite the rapid technological changes which have taken place in the past few years, disrupting almost all facets of our lives, there has been a marked decline in access to justice since the 2008 recession. In a report published on 16 September 2019, the... Where should the holding company be? In any cross-border merger transaction, an early question will often be where the holding company for the merged group should be located.  This is not just a tax question - the location of the business, stock market requirements and practical issues for t... Observations around Tax Certainty Today is the first OECD Tax Certainty Day. We have asked some of our authors for their thoughts on the topic. One of my fellow panellists at last week’s IFA Congress in London made this pertinent observation. In its work on developing a global anti-base e... A new Protocol will significantly amend the U.S.-Spain Tax Treaty On 27 November 2019, the U.S.-Spanish Tax Treaty, which dates back to 1990, will be significantly amended by the entry into force of a new Protocol. In most cases, the Protocol eliminates taxation at source, creating significant savings and consequently f... Google settles its French tax disputes for EUR 1 billion On September 12, 2019, the US tech giant Google agreed to pay close to EUR 1 billion to settle both a criminal investigation for tax fraud by the French Prosecution Office and an ongoing dispute with the French tax authorities focused on the existence of ... ECJ Danish cases: can we have a clear user manual, please? It is more than six months since the ECJ’s decisions in the Danish beneficial ownership cases, but taxpayers and tax practitioners are still trying to get to grips with what the decisions will mean in practice.  There are those who think the consequences ... UK CFC rules and EU State aid: an update A lot has happened since April when the European Commission published its full decision on the UK’s CFC rules explaining why it considers that the CFC rules for exempting non-trading finance profits constituted State aid to the extent that the relevant si... What should your non-tax colleagues know about DAC 6? DAC 6, the 2018 amendment to the Directive on Administrative Cooperation, is top of many tax adviser's worry list.  Tax advisers involved in international transactions have become intermediaries. And those of us who are in the EU will have to report to ou... Update on German Real Estate Transfer Tax (RETT) Reform What is it all about?  The public perception, pushed by politicians and the press, is that the German real estate transfer tax (RETT) applies unfairly: while every transfer of real estate itself is subject to RETT, it is assumed that the shares in real es... Dawn raids and data dumps: handling the practical realities of tax disputes In the past, many tax disputes were run as technical debates, where the parties (largely) agreed the facts, the court had little contested evidence to consider, and the focus was on the precise interpretation of the law.  That is no longer the case – and ...