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Spanish National Court follows CJEU in placing burden of proving abuse on Spanish tax authorities
In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish tax authorities and that the Spanish anti-abuse rule infringes European Union law. The ruling represents a turning poi...
Exit tax: holding companies may not qualify for Italian participation exemption on migration
The Italian Tax Authority confirmed that the participation exemption does not apply to shareholdings that are transferred abroad as part of a going concern (Principle of Law 10/2021). It follows that the participation exemption should be unavailable to mi...
UK announces post-Brexit trade deal with Australia
On 15 June 2021, Boris Johnson announced that the UK had agreed the broad terms of a free trade deal with Australia following a meeting with the Australian Prime Minister, Scott Morrison, with an “Agreement in Principle” expected to be published in the co...
ECJ Lexel AB decision casts a shadow over Dutch interest limitation provision
The decision of the European Court of Justice in the Lexel AB case raises questions whether the valid business reason exception of article 10a of the 1969 Dutch corporate tax act (CTA), an interest deduction limitation provision, is partly incompatible wi...
Stamp duty goes officially online - finally!
HMRC's press release heralds the decommissioning of the stamp duty press machines as the "end of an era" as the 300-year old process of manually stamping documents to evidence that the required transfer tax has been paid is (officially) going digital from...
Is the G7’s agreement on international tax reform really “seismic”, or is it too soon to tell?
Before the G7 Finance Ministers’ communiqué of 5 June announcing an agreement in principle (which was endorsed by the G7 leaders according to their communiqué of 13 June), the biggest news in international tax had been a renewed engagement of the US with ...
Is the G7’s agreement on international tax reform really “seismic”, or is it too soon to tell?
Before the G7 Finance Ministers’ communiqué of 5 June announcing an agreement in principle (which was endorsed by the G7 leaders according to their communiqué of 13 June), the biggest news in international tax had been a renewed engagement of the US with ...
Public CbCR to be implemented in the EU
Public country-by-country reporting is set to be implemented across the EU (including for non-EU headquartered groups) by early 2023 to take effect, at the latest, for the first financial year starting on or after early 2024. On Monday, 14 June 2021, the ...
European Commission finds preliminary concerns in respect of Internet of Things
The European Commission has found preliminary competition concerns in its sector inquiry into the rapidly-expanding Internet of Things. The initial findings, which focus on voice assistants such as Amazon's Alexa, Apple's Siri and Google Assistant, identi...
Get set, update! European Commission publishes finalised SCCs for data transfers
On Friday 4 June 2021, the European Commission published the final version of its long awaited standard contractual clauses for transferring personal data outside of the EEA (SCCs). The new SCCs include some welcome developments, including better alignme...