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Penalties for failure to make a DAC6 report and the right to a fair trial Authorities may not impose penalties on individuals for refusing to provide information that may prove their criminal liability or liability for an offence that is punishable with administrative sanctions of a criminal nature, meaning a sanction where its...
The difficulties with deeming - VAT, groups and time of supply Clashes between deeming provisions in a complex tax code inevitably give rise to tricky technical questions and, quite often, litigation.  The recent case of The Prudential Assurance Company Limited presented the First-Tier Tribunal with such a conundrum...
UK Government non-committal on Select Committee’s recommendations regarding AI strategy The UK government has provided its response to the House of Lords Select Committee on Artificial Intelligence’s report ‘AI in the UK: No Room for Complacency’ (the “2020 Report”). The 2020 Report, published 18 December 2020, examined the progress made by...
Cutting the oxygen on cybercrime: Nominet expands law enforcement landing pages Think that you are too smart for the cyberscammers? The Medicines and Healthcare products Regulatory Agency (MHRA) reported that 1 in 10 people in the UK have bought fake medical products online in 2020. The Financial Conduct Authority (FCA) reported an...
Does some Member States' implementation of the legal professional privilege exemption from DAC6 reporting infringe higher-ranking Union standards? The way in which some Member States have implemented DAC6 raises legitimate concerns on its validity and compatibility with higher-ranking European Union standards. There is some reasonable doubt as to whether the legal professional privilege exemption...
Income tax free securitisation of real estate in Italy In a recent ruling (No. 132 of 3 March 2021) the Revenue Agency has confirmed that SPVs used to secure proceeds from the direct ownership of real estate and most of their non-resident investors enjoy full direct tax exemption in Italy. “ReoCo” in the...
DAC6 and legal professional privilege - request for a preliminary ruling On 21 December 2020, the Belgian Constitutional Court (Grondwettelijk Hof) requested a preliminary ruling from the CJEU on the DAC 6 rules, as transposed in Belgium (Case C-694/20), in the context of proceedings brought by the Flemish Bar Association...
The corporation tax rise in pictures... For those who prefer to think in pictures, this chart from the OBR's 2018 report "Why have onshore CT receipts performed so well since 2013-2014?" is a very neat illustration of the balance of measures that have more or less offset each previous cut of...
Has the Chancellor really just announced a UK corporation tax rise of over 30%? TLDR – yes, it seems he has. The Chancellor is still trumpeting the rate as the lowest in the G7, even after the rise. But for those watching as the effective corporate tax rate shoots up above those of many of the UK’s competitors, the impact on the UK’s...
UK’s March 2021 Budget: Spend now – pay later The UK’s headline corporation tax rate is set to rise to 25% from April 2023 (with a commensurate increase in the diverted profits tax rate) – but, in the short-term, economic support will continue, including through an enhanced loss carry-back, and a...