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BLOG: New double taxation agreement between the UK and Brazil In September 2022, Brazil and the UK announced a first round of negotiations for a double taxation agreement (DTA) following several years of discussions on technical and policy issues. It appears that the formal negotiations progressed well, given that a...
Employment Bulletin - November 2022 Topics covered in this bulletin: Future employment legislation CAC’s jurisdiction over European Works Councils post Brexit Dismissal “vanished” on successful appeal even though employee did not want reinstatement Horizon...
Competition & Regulatory Newsletter: Court of Justice issues judgment in Fiat State aid case On 8 November 2022, the European Court of Justice handed down its judgment in the Luxembourg and Fiat case, finding that the European Commission and the General Court had erred in their conclusion that Luxembourg had granted unlawful State aid to Fiat....
COP27 – Summary of key announcements A breakthrough emerged on Sunday morning, with the announcement that almost 200 countries had agreed to set up a fund to cover the “loss and damage” that vulnerable nations are suffering due to climate change – a particularly contentious...
BLOG: A capital mess? The Court of Appeal’s judgment in Centrica Overseas Holdings In what is thankfully an unusual occurrence in legal practice, I was about to press send on an email advising a client on an issue (in this case, the deductibility of expenses incurred in respect of the sale of a subsidiary), very much relying on the...
Tax and the City Review for November 2022 Mike Lane and Zoe Andrews discuss the VAT decisions of the CJEU in O Fundusz (sub-participation agreements) and of the Supreme Court in NHS Lothian (VAT recovery), HMRC’s Guidelines for Compliance, the OECD’s report on tax incentives and the...
Solvency UK - Results of the Solvency II Review In this briefing note we discuss the results of HM Treasury's review of UK Solvency II, including key changes to the risk margin and the matching adjustment to release capital held by insurers and facilitate investment in long-term productive assets....
BLOG: Further changes to the UK's R&D tax regime Against a background of some “difficult decisions” being taken by Chancellor Jeremy Hunt in his 2022 Autumn Statement on 17 November 2022, the Treasury unveiled some further changes to the UK’s Research and Development (R&D) tax regime, signalling a...
The Legal 500: Blockchain Country Comparative Guide 2022 - Hong Kong chapter The Blockchain Country Comparative Guide aims to provide an overview of the law and practice of blockchain law across a variety of jurisdictions. This chapter relates to Hong Kong law.   Please provide a high-level overview of the blockchain...
BLOG: Taxing decisions in the Autumn Statement Undoubtedly, the UK’s Autumn Statement delivered by Chancellor Jeremy Hunt on 17 November 2022 reflected some difficult decisions (see the Treasury’s news story and the text of his speech). But at least the one relating to the GloBE rules under Pillar 2...