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US Government finalizes rules on transfers to partnerships with related foreign partners In an effort to close the door to a potentially abusive tax scheme involving partnerships with related foreign partners, the US government issued final regulations on 17 January 2020.  The regulations, which generally apply to transfers occurring on or af... OECD reviews Country-by-Country Reporting, suggesting possible extensions The OECD has released the consultation document for its review of Country-by-Country Reporting which forms part of the standardised approach to transfer pricing documentation established under Action 13 of the BEPS Project (see press release). The review ... CJEU fails to provide clarity on the term ‘computer software’ for trade marks The CJEU last week had the opportunity to rule on whether the term ‘computer software’ was too broad for the purposes of a trade mark registration. The case considered various questions of trade mark law, including if it was possible to obtain trade mark ... Will rejecting the EU’s new copyright directive #savetheinternet? In a U-turn against its policy under Theresa May’s government, the UK has indicated that it will not implement the EU’s new Directive on Copyright in the Digital Single Market (the "Directive”) now it has left the EU.  On 16 January 2020, UK Minister fo... A new year, a new privacy law for Hong Kong? The Hong Kong government has proposed wide-ranging reforms to its data privacy law, the Personal Data (Privacy) Ordinance (Cap 486) (“PDPO”).  The contemplated reforms, first discussed in the legislature in January 2020, would be the most radical overhaul... Dutch Supreme Court denies benefits of EU Directive to 'wholly artificial' LuxCo structure For the first time, the Dutch Supreme Court has denied the benefit of the EU Parent-Subsidiary Directive based on the existence of a 'wholly artificial arrangement'. It decided that a dividend paid by a Dutch holding company to a Luxembourg holding compan... International tax reform: one step forward? The Inclusive Framework's update on its two-pillar approach to addressing the tax challenges of the digitalisation of the economy has clarified the scope of Pillar One - the outline of the architecture of a unified approach has been agreed. Progress has a... International tax reform: one step forward? The Inclusive Framework's update on its two-pillar approach to addressing the tax challenges of the digitalisation of the economy has clarified the scope of Pillar One - the outline of the architecture of a unified approach has been agreed. Progress has a... Can your AI machine be an inventor? The EPO says no…. The European Patent Office (EPO) has published its grounds for refusing two patent applications which named an AI machine as the inventor. In November the EPO rejected patent applications that designated an AI machine named “DABUS” (Device for the Autonom... New product liability rules for AI? The European Commission has recently released a report from the Expert Group on Liability and New Technologies (an independent expert group set up by the Commission) that explores how product liability regimes should be designed – and, where necessary, ch...