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New AI standards hub launched in UK
This week the government launched a new AI standards initiative as part of its AI strategy (see my blog from last September for information on the strategy generally). New research predicts that AI use in business is expected to double in the next twenty ...
Full steam ahead for the UK’s implementation of the global minimum tax rules
When is the best time to consult on the UK’s implementation of the OECD/IF GloBE model rules published on 20 December 2021 with the aim of requiring large multinational groups to pay a minimum 15% level of tax in each jurisdiction in which they operate? N...
Finland amends its transfer pricing rules – long-awaited improvement or a new begin for transfer pricing disputes?
Finland has amended its transfer pricing rules as of January 2022 enabling the Finnish Tax Administration (FTA) to make transfer pricing adjustments to the full extent permitted by the OECD Transfer Pricing Guidelines. Until now the FTA has had to accept,...
UK regulatory reform in 2022 (part 2)
As mentioned in our 'UK regulatory reform in 2022 (part 1)' blog, UK regulatory reform pushes on, with its key drivers of bolstering the UK’s position as a global financial centre and, as the UK Chancellor stated in a Speech in July 2021, a financial serv...
UK regulatory reform in 2022 (part 1)
UK regulatory reform pushes on, with its key drivers of bolstering the UK’s position as a global financial centre and, as the UK Chancellor stated in a Speech in July 2021, a financial services sector that is ‘open, competitive, technologically advanced a...
Proposal to amend rules on VAT Directive rates
On 7 December 2021, the EU Council agreed on a proposal to update rules on value added tax (VAT) rates. This proposal builds on the 2016 VAT Action Plan - Towards a single EU VAT area which aims to put in place a “definitive VAT system” based on the princ...
The Spanish minimum 15% CIT rate: at the vanguard of the OECD/IF tax reform or in breach of a global agreement?
For tax years starting as of 1 January 2022 or later, a minimum effective 15% Corporate Income Tax (CIT) will apply to large Spanish resident CIT payers, including tax consolidated groups, as well as Spanish permanent establishments. According to the Span...
Concerns about cross-border mergers of Chilean companies
Legal regulation of Chilean non-recognition regimes is scarce. Further details of their requirements are often derived from regulations and rulings of the Chilean Internal Revenue Service (IRS), on which taxpayers can rely. This is also true in the case o...
The “Danish cases” controversy: the Spanish Tax Authority makes its move
Following the path of tax audits stemming from the ECJ’s rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax Authority has taken an official position on the subject by publishing a report that concludes that the special anti-abuse proc...
Global minimum tax model rules
The model rules for Global Anti-Base Erosion (GloBE) (a.k.a. Pillar Two of international tax reform) set a template for a jurisdictional-level corporate minimum tax system applying a minimum effective rate of tax (ETR) of 15%. This is expected to generate...