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GloBE Administrative Guidance In order to achieve consistency, any jurisdiction adopting the global minimum tax or “GloBE” rules has to follow the Model Rules and the Commentary as amended from time to time by Administrative Guidance. This guidance is expected to be issued on a rollin... Are the Floodgates Opening? The Future of Large Datasets in AI The use of large third-party datasets in the development of AI models has been a contentious issue for some time now.  In the latest development, Getty Images are bringing a copyright claim in the UK against AI developer Stability AI, in relation to Stabi... Cryptoassets: the next chapter Yesterday, HM Treasury published its much anticipated vision for the future of the financial services regulatory regime for cryptoassets. Comprehensive, detailed, and 82 pages long, this consultation paper and call for evidence brings some coherence to an... Crypto: Promo Go Slow (Part 2) Just a week after the FCA's review of AML registration applications by crypto firms, we've now got two important publications from the UK government on the future regulation of cryptoassets. It feels like they're my 43 bus from London Bridge (or perhaps m... Crypto-ing the line Back at the very beginning of 2020 Covid-19 still hadn't been designated a pandemic, Brexit still wasn't quite 'done' and you could start a cryptoasset business in the UK without needing to so much as notify the FCA you were doing so.  In the intervening ... New limitation on the offsetting of tax losses generated in 2023 by entities taxed under the Spanish CIT consolidation regime This post provides an overview of the Spanish legal framework applicable to the use of carried forward tax losses (NOLs) and briefly analyses the temporary limitation introduced by the recently published Law 38/2022, of 27 December, regarding the use of t... To borrow or not to borrow: key considerations for “venture debt” deals If you are a tech start-up, or your organisation invests in or helps develop them, you will have seen market speculation that 2023 is likely to be a difficult year for tech businesses to raise venture capital. At the end of last year, we set out some key ... ICAAPS, ILAAPS, recovery plans and now, carbon transition plans? Under the draft Capital Requirements Directive VI (the Draft), European credit institutions will be required to prepare and update annually ‘carbon transition plans’. Although the Draft mandates the European Banking Authority (EBA) to flesh out their cont... Share deals in peril of double taxation under new RETT law The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares in an entity holding real estate located in Germany. Pursuant to this theory, the conclusion of the agreement (signing)... CJEU says Amazon may be liable for trade mark infringement for sale of counterfeit Louboutins The Court of Justice of the European Union (“CJEU”) has held that online sales websites like Amazon that operate a “hybrid” business model (offering both the operator’s own sales as well as a marketplace for third parties) may be liable for trade mark inf...