12/18/2020 12:00:00 AM Corporate tax residence: latest from the Court of Appeal By Tanja Velling Zoe Andrews In the latest instalment of the Development Securities litigation, the Court of Appeal unanimously overturned the Upper Tribunal (UT)...
12/17/2020 12:00:00 AM Dutch Supreme Court rules on applicability of participation exemption in the context of uncovered call options and benefits from German cum/ex trades By Ingrid Mensing Recently, the highest court in the Netherlands ruled that (a) uncovered call options cannot be regarded as a participation, and (b)...
12/16/2020 12:00:00 AM More questions than answers in the Gallaher appeals By Zoe Andrews The Upper Tribunal has decided in the Gallaher case that a number of questions should be referred to the CJEU prior to the end of the...
12/14/2020 12:00:00 AM Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent” By Victor Camatta Pierre-Marie Roch In a decision dated 11 December 2020 (no 420174), the French Administrative Supreme Court (Conseil d’Etat) overturned the decision of the...
12/11/2020 12:00:00 AM Carbon Pricing: making polluters pay post-Brexit By Angus Tyrrell In many countries carbon pricing has become a key part of the journey to decarbonisation. Currently, the World Bank reports that there...
12/10/2020 12:00:00 AM VAT and the sharing economy By Mike Lane Yesterday HMRC published a call for evidence on VAT and the sharing economy. It is another piece in the puzzle of whether and how tax...
12/10/2020 12:00:00 AM EU-UK double tax treaty dispute resolution after 2020 By Tanja Velling With effect from the end of the Brexit transition period, the UK will revoke the Double Taxation Dispute Resolution (EU) Regulations 2020...
12/9/2020 1:40:24 PM Northern Ireland Protocol: agreement in principle By Tanja Velling The co-chairs of the EU-UK Joint Committee stated that, following their meeting on 8 December 2020, agreement in principle had been...
12/8/2020 2:02:55 PM Taxing multinationals: what the statistics reveal By Zoe Andrews The net yield from the UK’s diverted profits tax (DPT) since it was introduced in April 2015, is £386m according to the latest statistics...
11/19/2020 2:39:39 PM Foreign investment funds may be eligible for Dutch dividend withholding tax refunds By Ingrid Mensing The Dutch Supreme Court decided in the Köln Aktienfonds Deka (KA DEKA) case that foreign investment funds are eligible for a refund of...
11/17/2020 9:10:46 AM The discrimination introduced by the non-French resident capital gains tax is not covered by the EU standstill clause: timing is of the essence! By Franck Morhain Victor Camatta The Administrative Court of Appeal of Versailles has recently ruled that the capital gains tax charge applicable to non-residents on the...
11/16/2020 1:54:04 PM Italian “mixed takeover bids" are not tax neutral By Michele Dimonte In principle, a “takeover bid” means a public purchase offer, whether mandatory or voluntary, made to the holders of securities in a...
11/13/2020 9:12:33 AM How Brexit might limit challenges to HMRC decisions By Tanja Velling Looking at the CJEU decision in Luxembourg v B in the context of the UK's proposed new Financial Institution Notice (which would allow...
11/12/2020 6:45:55 PM Main highlights of 2021 Spanish tax reforms By Javier Arregui Alex Pié Shortly after the approval of the new Financial Transaction Tax and Digital Services Tax, the Spanish Government has submitted to...
11/11/2020 11:34:58 AM Spanish scrip dividends: Let the shareholder decide! By Miloslava Ilcheva In the last years, scrip dividends had become a very popular equity remuneration scheme for Spanish listed companies, as it helped them...
11/10/2020 10:38:10 AM IP taxation: German nexus in unexpected circumstances By Sebastian Heinrichs The German Ministry of Finance (BMF) published the first guidance on one of the most hotly discussed German tax issues of the year on...