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ECJ beneficial ownership cases: the end of the Dutch safe harbor rules in sight? Two ECJ rulings of 26 February 2019 cast doubt on whether safe harbour rules applied by the Netherlands are compliant with EU law.  Under these safe harbour rules, an abuse of EU law is deemed not to exist, and consequently benefits under the Interest and... EU State aid decision on UK CFC rules The full decision in the EU State aid investigation into the UK CFC rules for non-trading finance profits (“NTFP”) has now been published.  In summary, whilst the Commission accepted that NTFP might raise a higher risk of artificial diversion of profit, i... Digital Services Tax in Spain - the world inside-out? With the OECD issuing its February 2019 public consultation, in which a consensus-based and long-term solution for the taxation of the “digital economy” begins to be sought, the Spanish Government seems to be adamant on the potential introduction of a Dig... UK tax free cross-border transfers In the recent case of Gallaher, the UK’s First-tier Tax Tribunal reached a surprising conclusion on the UK’s intra-group transfer regime. Section 171 TCGA allows assets to be transferred within a tax group on a “no gain/no loss basis”, so long as the asse... International tax reform: marketing intangibles proposal attracts support The "marketing intangibles" proposal has emerged from the OECD's public consultation discussions as the most likely of the OECD's proposals to achieve a consensus from the (now 129) countries that are committed to finding a global solution to the challeng... The ICO is dead, long live the ICO Extract from the winning essay in a competition for young lawyers jointly sponsored by the Banking Law Committee and Securities Law Committee. Abstract Cryptocurrencies. Tokens. ICOs. The buzzwords of the moment. But what exactly are they and what is caus... New P2B rules get ready to hit the books A ride home, a Thai takeaway, a new padlock for the shed, an app to entertain my toddler -- all goods and services I've purchased on online platforms in the last week without a second thought as to how quick, convenient and inexpensive the transaction was... Coding and collaboration Last month our collaboration space was the venue for an experiment, an internally-led and designed coding workshop. Twelve participants - a mix of trainees, associates, PSLs and members of business services - were supported over three sessions through an ... AI and the effect on tax allocation Discussions continue at a global level on how the international tax rules should be reformed so they work adequately for today’s business models. A particular focus has been the problems associated with highly digitalised business, although some countries... Held to ransom in the digital age - what can financial institutions do? Recent research has shown that ransomware is not going away. In fact, researchers have warned that the type of cyber-attack in which access to critical systems, information and/or services is withheld until a ransom is paid to the attacker is becoming mor...