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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...
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...
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...
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...
Austria tackles the digital economy Austria is planning to raise more than 200 million euros per annum in taxes from the digital economy. This apparently represents 0.2 percent of Austria’s total 2018 tax income. Two thirds of this tax is expected to come from phasing out the low value...
The hidden fight on my phone I have an epic daily commute. One advantage I have is being at the end of the line, meaning I always get a seat. I sit back, relax and, thanks to my trusty iPhone, am whisked far away from the Central Line. That is, unless I've made the rookie mistake of...
Taxing the sharing economy In 2017 the OECD asked a group (made up of the UK and Italian tax authorities) to look at how countries could ensure that income from the sharing and gig economy (such as Airbnb, Uber, Deliveroo and eBay) was taxed effectively.  The group published its...