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A capital mess? The Court of Appeal’s judgment in Centrica Overseas Holdings In what is thankfully an unusual occurrence in legal practice, I was about to press send on an email advising a client on an issue (in this case, the deductibility of expenses incurred in respect of the sale of a subsidiary), very much relying on the Uppe... Further changes to the UK's R&D tax regime Against a background of some “difficult decisions” being taken by Chancellor Jeremy Hunt in his 2022 Autumn Statement on 17 November 2022, the Treasury unveiled some further changes to the UK’s Research and Development (R&D) tax regime, signalling a move ... The ICO publishes tips on how to improve your use of AI The ICO has published new AI guidance, setting out its top tips on how to use AI and personal data appropriately and lawfully. It can improve how your organisation handles AI and personal data. It is also intended to help regulators understand how AI can ... ICO publishes new set of international data transfers guidance Today, the ICO has published a suite of new international transfers guidance, including its long awaited final guidance on ‘transfer risk assessments’ (TRA). The new guidance follows the ICO’s consultation on international data transfers during the summer... Taxing decisions in the Autumn Statement Undoubtedly, the UK’s Autumn Statement delivered by Chancellor Jeremy Hunt on 17 November 2022 reflected some difficult decisions (see the Treasury’s news story and the text of his speech). But at least the one relating to the GloBE rules under Pillar 2 m... The UK's proposed small banks' prudential regime The PRA's first consultation on its proposed simplified regime for smaller non-systemic banks and building societies (the Small Banks Regime), published earlier in 2022, has generated a fair amount of feedback from different stakeholders. As well as banks... The UK's future regulatory framework Following the UK's Treasury Department response to its final consultation on its review of the UK regulatory framework (the Review), its proposals, largely unamended following consultation feedback, are being legislated for through the Financial Services ... German Tax Authorities publish long awaited guidance on new RETT law The 2021 reform of the German Real Estate Transfer Tax Act (Grunderwerbsteuergesetz or GrEStG) included, among other things, three important changes.  Under the revised Partnership Rule in §1(2a) GrEStG, the transfer of at least 90% of the interests in a ... Transfer pricing and EU State aid – CJEU reaffirms national tax autonomy and annuls Commission’s decision in Fiat case Where should the line be drawn between the prohibition on State aid and Member States’ fiscal autonomy? According to the Commission and the General Court, the Luxembourg tax ruling given to Fiat fell on the wrong side of this line and constituted unlawful... Hold On! There’s no Hold Up or Hold Out When can a Standard Essential Patent (SEP) owner obtain an injunction against an infringer? The Court of Appeal clarifies in Optis v Apple. The Court of Appeal has confirmed, in Optis v Apple, that once a UK SEP has been found valid, essential and infring...