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German RETT reform finally close to implementation in July 2021 The reform of the German Real Estate Transfer Tax (RETT) Act took a decisive step towards implementation. Since the RETT reform focuses on share transactions relating to all corporations and partnerships owning German real estate, this is relevant for a...
The long-awaited Euromoney decision has finally appeared. But is it right? For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test. Both have now resulted in victory for the taxpayer, through the agency of Kevin Prosser QC, and both show yet again the...
Taxing Tokens The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad disappointing that HMRC's cryptoassets manual, which it updated recently, still seems in places to use the terms "cryptoasset"...
Taxing Tokens The last few weeks have seen a number of cryptoasset milestones reach the mainstream press - in that context it is perhaps a tad disappointing that HMRC's cryptoassets manual, which it updated recently, still seems in places to use the terms "cryptoasset"...
Amsterdam Appeal Court: what are the limits to using post-dated OECD commentaries in interpreting a double tax treaty? The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of 16 March 1973 (the French-Dutch Treaty). The case involved the acquisition of a Dutch company by a French company...
French Administrative Supreme Court takes post-dated OECD commentaries into consideration in interpreting French-Irish double tax treaty In its decision in the Valueclick Case on 11 December 2020, the French Administrative Supreme Court ruled on the existence of a permanent establishment based on the dependent agent test within the meaning of Article 2 of the French-Irish double tax treaty...
AI developers – can you still get patents? The crusade of Dr Stephen Thaler, the DABUS machine and the ongoing debate on the impact of AI on patent law has dominated the patent landscape over the past year.  To some extent, it has overshadowed another equally important issue in light of the rapid...
To what extent can post-dated OECD commentaries be taken into account in interpreting a double tax treaty? This question - which is of utmost importance as the OECD commentaries provide key insights to tax authorities, taxpayers and judges, on how a double tax treaty shall be applied - is highly debated among the OECD member countries. Reasserting a...
Close collaboration: operational resilience and cyber resilience Last week the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA) and the Bank of England published long-awaited policy statements and supervisory materials setting out their final rules and guidance on operational resilience....
The Netherlands proposes new legislation to deal with asymmetrical transfer pricing adjustments On 4 March 2021, the Dutch government presented a draft bill for comments by interested parties introducing fundamental changes to Dutch transfer pricing rules. If enacted, the new rules would apply as of 1 January 2022, with material retroactive effect...