12/20/2019 3:30:10 PM German Draft ATAD II Implementation Act By Sebastian Adam On December 10, 2019, the German Ministry of Finance published draft law which is intended to implement Article 9 and 9b of the Anti Tax...
12/13/2019 4:47:08 PM Dividend withholding tax: from abolition to reinforcement By Maarten van der Weijden Political developments are hard to predict. The case of the Dutch dividend withholding tax is a prime example of how quickly the...
12/13/2019 1:42:30 PM HMRC Statement on State Aid Recovery By Mike Lane Happy Friday the 13th! Taxpayers who claimed the benefit of the UK’s CFC finance company exemption before 1 January 2019 will have shaken...
12/3/2019 12:00:00 AM The US's reaction to France's DST By Slaughter and May In her recent post, Zoe Andrews suggested that, given the importance for the UK of securing a post-Brexit trade agreement with the US,...
12/3/2019 12:00:00 AM Fixed establishment through parent-subsidiary relationship By Michele Dimonte In Case C-547/18, Dong Yang Electronics, the ECJ has been asked to revisit the definition of fixed establishment (FE) for VAT purposes...
11/29/2019 12:00:00 AM What does independent taxation mean? By Slaughter and May The Labour Party has been in trouble this week due to its promise to scrap the UK tax marriage allowance. This allowance was introduced...
11/27/2019 3:19:08 PM Easier access for EU CIUs, AIFs and pension funds to Spanish tax exemption By Guillermo Canalejo New rules will significantly ease the access by qualified Collective Investment Undertakings (CIUs), Alternative Investment Undertakings...
11/26/2019 10:20:56 AM Is now a good time for a UK digital services tax? By Zoe Andrews The message was clear at last week's OECD public consultation on the reform of the international tax rules that there is a need to fix...
11/26/2019 12:00:00 AM Labour's Fair Tax Programme: the £6.2bn question... By Mike Lane ...or "Seeing as everyone else is now giving 'fact-checking a go'". When Labour published its 2019 Election manifesto last week it was...
11/15/2019 12:00:00 AM Is it time to reconsider policy on bank taxation? By Zoe Andrews As discussed in my Viewpoint video, the UK government is heavily reliant on taxes paid by financial services. The finance and insurance...
11/12/2019 12:00:00 AM GloBE: learning the lessons of the past By Mike Lane The OECD published its Pillar Two paper on the Global Anti-Base Erosion (GloBE) Proposal on Friday (Zoe Andrews' earlier post provides an...
11/11/2019 1:46:28 PM Towards a "smart" VAT system? By Slaughter and May We live in a world of burgeoning automation. Transactions are increasingly automated in a range of ways, from direct debit (around since...
11/8/2019 5:07:59 PM Gibraltar companies outside the scope of the Parent-Subsidiary Directive By Tanja Velling Michele Dimonte On 24 October, Advocate General (AG) Hogan opined that a company incorporated, and subject to corporation tax, in Gibraltar cannot avail...
11/8/2019 3:23:58 PM Consultation on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two By Zoe Andrews Another day, another proposal to substantially change the international tax architecture. This time it is the GloBE Proposal under...
11/8/2019 12:00:00 AM The ORIP rules: intangible property held in the Crown Dependencies By Tomás McGrath It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies...
11/4/2019 4:32:30 PM US Treasury Department Loosens “Earnings Stripping” Rules By J. Leonard Teti II The latest salvo in a years-long struggle to administer US “earnings stripping” rules took another turn on 31 October, when the US...