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Supreme Court in Prudential Assurance clarifies interaction of VAT grouping and time of supply rules Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for the services comprises a quarterly management fee and success fees. The success fees depend on investment performance... Privilege in UK tax disputes: Five questions answered HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask for them. Careful thought is required when assessing if a document really is privileged (and so can be withheld) and, ... Spain’s National Court recognises non-EU taxpayers’ right to be taxed on a net basis, by deducting expenses against their Spanish source income In a landmark decision, Spain’s National Court (Audiencia Nacional) has applied CJEU case law on the free movement of capital to conclude that non-EU/EEA taxpayers subject to the Non-Resident Income Tax (NRIT) are entitled to deduct expenses directly rela... Zalando loses its challenge against DSA VLOP designation On 3 September 2025, the General Court of the European Union delivered the first major judicial interpretation of the DSA in its dismissal of Zalando’s challenge against its designation as a “very large online platform” (“VLOP”) under the EU’s Digital Ser... German Federal Fiscal Court rules against double RETT on share deals In a decision dated 9 July 2025, the German Federal Fiscal Court (docket no. II B 13/25) addressed the issue of a double assessment of real estate transfer tax (RETT) in share deals, where the contractual obligation transaction (signing) and the actual tr... How to respond to information requests from HMRC A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes in the UK, we discussed what to look out for when HMRC open an enquiry – and noted that enquiries often go on for years... What to do when HMRC open an enquiry Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of HMRC enquiries – which will often last for years, given that there is no statutory time limit for HMRC to complete an... How to handle tax disputes in the UK Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the reiteration of government promises not to increase taxes on working people, it can be expected that HMRC will continue to seek t... The fair necessities: DMCC Act and unfair commercial practices under the microscope Earlier this year, the majority of the unfair commercial practices (“UCPs”) provisions in the Digital Markets, Competition and Consumers Act 2024 (the “DMCC Act”) came into force and the Competition and Markets Authority (CMA) published guidance explainin... Data claims must be proved: lessons from the Court of Appeal on non-material damage Ever since Lloyd v Google [2021] stemmed the flow of mass data protection litigation, potential claimants have sought new ways to bring claims against controllers that, by accident or design, have ‘mishandled’ individuals’ their data. The recent Court of ...