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Discriminatory tax treatment of foreign Real Estate Investment Funds (REIFs) Are closed-ended Italian REIFs and open-ended REIFs in a comparable position for Italian indirect tax purposes? The ECJ is set to address this question within months (C-479/19). The request for a preliminary ruling was referred by the Italian Supreme...
Putting the ML into AML The FCA and Bank of England have recently published the findings of their first ever survey of the use of machine learning (ML) in financial services firms. The conclusions from the survey are that there has been significant uptake and deployment of ML in...
Conforming interpretation revisited The UK’s First-tier Tax Tribunal's decision in Panayi has been published. Whilst the case was reminiscent of Gallaher  (previously discussed by Sara Luder), the Judge reached what looks like an opposing conclusion.  Panayi  concerned a capital gains tax...
Freedom to move capital to (or from) overseas territories Transfers between the UK and Jersey are, according to the UK Supreme Court, within the scope of the freedom of movement of capital under what is now article 63 of the Treaty on the Functioning of the European Union.  Routier v HMRC concerned a potential...
The General Court’s Starbucks and FIAT rulings: what’s new and what’s not The long-awaited judgments by the General Court of the EU – on whether unlawful stated aid purportedly granted by the Netherlands and Luxembourg to Starbucks and FIAT – have received much public attention. And with good reason. While applying state aid...
Dutch 2020 Budget: the end of an era The Dutch government has released its budget plans for 2020, as well as certain tax proposals. The introduction of a withholding tax on interest and royalties marks a significant policy shift. This measure and other key items of interest for international...
Introducing Insta-contracts In pursuit of reaching a wider audience, the New York Public Library (NYPL) recently ran a project to adapt classic literature to Instagram’s small screen story format. The NYPL worked alongside design agencies to prepare easily digestible content. The...
Overview of the 2020 Irish Budget – key tax measures On 8 October 2019, the Irish Minister for Finance made his 2020 Budget speech to the Irish Parliament. A number of unexpected measures were introduced by way of Financial Resolution with immediate effect. The remaining measures will be introduced through...
Dispute risk under the OECD Secretariat's “unified approach” In her overview of the OECD Secretariat's "unified approach",  Zoe Andrews mentioned that a robust dispute prevention and resolution mechanism will be needed.  Ease of administration is going to be important for market countries and multi-national...
The Future of Financial Regul-AI-tion We are proud to have contributed to a report on the opportunities afforded by artificial intelligence in the financial and professional services industry, which was published by the International Regulatory Steering Group yesterday. The report contains a...