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Taxpayer wins double tax treaty purpose test case With Article 7 of the OECD's Multilateral Instrument containing a Principal Purpose Test (or PPT) tax authorities, taxpayers and tax advisers alike are going to have to spend more time in the future considering when an arrangement or transaction might be...
UK advances multinational top-up tax despite mostly a lack of progress elsewhere The US has finally passed some tax legislation in the form of the Inflation Reduction Act. But before you get too excited, it does not implement either of the two pillars of international tax reform. Disappointingly, there are no changes to the US GILTI...
Tornado Cash: US Treasury sanctions virtual currency mixer On Monday 8 August the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned virtual currency mixer Tornado Cash, which operates on the Ethereum blockchain and which, in the words of OFAC, "indiscriminately facilitates...
Euromoney: Taxpayer prevails before the Upper Tribunal At first instance, Euromoney had been decided in favour of the taxpayer and my colleague’s post on the decision surmised that “HMRC may be so disheartened by the FTT’s factual findings that they abandon the fight”. This did not come to pass. HMRC appealed...
BlackRock revisited: what is the purpose of the “unallowable purpose” rule? That might sound like a strange question, but it lurks just beneath the surface of the Upper Tribunal’s keenly-awaited decision in BlackRock which is the latest instalment in a series of “unallowable purpose” cases including Kwik-Fit and JTI. The case...
A “background hygiene factor”? The UKIPO publishes its study on IP and investment in AI In its recent study on IP and investment in AI, the UK Intellectual Property Office (“UKIPO”) considered the extent to which the UK’s IP framework influences decisions on UK investment in AI. Ultimately, the study found that the UK’s IP framework is...
Introducing the UK’s Data Protection and Digital Information Bill “Through this Bill we will realise the opportunities of responsible data use whilst maintaining the UK’s high data protection standards.” This was how the new Minister for Media, Data and Digital Infrastructure, Matt Warman MP, framed the new Data...
Crypto winter, regulatory spring Until not so long ago, lawyers like me would have to trawl the internet for a whispered mention of crypto from a regulator, and it took quite a long time to explain my interest in the subject at a dinner party. Now, it is difficult to go more than a few...
PSD2: EBA publishes its final guidelines on the limited network exclusion The second Payment Services Directive ((EU) 2015/2366) (“PSD2”) introduced an exclusion from its scope for services based on specific payment instruments that can be used only in a limited way. Payment instruments that might benefit from the limited...
Succeeding by Design: Government considers changes to UK designs system The UKIPO has published its response to its Call for Views on the UK’s designs system. Although the UKIPO has provided no firm policy proposals or concrete conclusions on the questions raised, the consultation and related responses cover a number of...