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Cutting out the middle man: Digital Regulatory Reporting On 7 April 2020 the FCA published its 2020/21 Business Plan announcing that, in addition to its key priorities, one of its cross-sectoral priorities will be further work in the sphere of innovation and technology. In particular, the FCA intends to invest...
First Spanish rules on the taxation of carried interest For the first time, the Basque Country  and Navarre have enacted regulations on the Personal Income Tax treatment of carried interest. But it is currently unclear whether the new regimes, which reduce the tax burden on qualified carried interest income,...
Tax residence post-MLI Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD) residence tie-breakers have been removed from some of the UK's tax treaties in favour of competent authority determinations....
Fastest finger first? Nominet opens consultation on expiring .uk domains Highly desirable… Diamonds? Willy Wonka’s “Golden Ticket”? Contested by multiple parties… The Iron Throne? Gone in seconds… Glastonbury tickets? In fact, we are talking about attractive expiring .uk domain names, for example, generic or short domains that...
House of Lords: we need an Online Harms Bill to save our democracy Lockdown has created a perfect storm of debate around online content. We are more reliant than ever on our social media drip-feed, which presents us with conspiracy theories and “fact-checks” political figures. Corporations have been pulling out of...
Brexit and Loan Agreements The impact of Brexit on loan agreements has been fairly limited to date. However, as the end of the implementation period approaches, and the legal and commercial realities of Brexit are expected to be felt for the first time, is this view likely to...
EPO filing statistics: is 3D printing due some hype (again)? Many predictions have been made about 3D printing over the years.  They have ranged from hype that every household would have its own 3D printer to being tracked on the Gartner Hype Cycle (with its emotive labels of plummeting to the ‘trough of...
Back to the future... When I first qualified into tax, UK-UK transfer pricing was not a thing.  A UK company could lend money to a fellow UK group company without being required to impute interest on the loan.  A UK parent could guarantee the loan of its UK subsidiary without...
Should platforms like YouTube be liable for illegal uploads? As in all good legal conundrums, the answer is ‘well that depends’. If you are Advocate General Saugmandsgaard Øe in the recent joined cases Frank Peterson v Google LLC, YouTube LLC and others (C-682/18) and Elsevier Inc. v Cyando AG (C-683/18), then no....
How will the end of the Brexit implementation period impact eligibility for ECB collateral and the ECB purchase programmes? In response to the Covid-19 pandemic, central banks across the world set out a range of monetary stimulus packages. One such scheme is the European Central Bank’s Pandemic Emergency Purchase Programme (“PEPP”), aimed at supporting Eurozone monetary policy...