Corporate tax residence: latest from the Court of Appeal
In the latest instalment of the Development Securities litigation, the Court of Appeal unanimously overturned the Upper Tribunal (UT)...
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Dutch Supreme Court rules on applicability of participation exemption in the context of uncovered call options and benefits from German cum/ex trades
Recently, the highest court in the Netherlands ruled that (a) uncovered call options cannot be regarded as a participation, and (b)...
More questions than answers in the Gallaher appeals
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...
Valueclick Case: French Administrative Supreme court rules in favor of a broad interpretation of “dependent agent”
In a decision dated 11 December 2020 (no 420174), the French Administrative Supreme Court (Conseil d’Etat) overturned the decision of the...
Carbon Pricing: making polluters pay post-Brexit
In many countries carbon pricing has become a key part of the journey to decarbonisation. Currently, the World Bank reports that there...
VAT and the sharing economy
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...
EU-UK double tax treaty dispute resolution after 2020
With effect from the end of the Brexit transition period, the UK will revoke the Double Taxation Dispute Resolution (EU) Regulations 2020
Northern Ireland Protocol: agreement in principle
The co-chairs of the EU-UK Joint Committee stated that, following their meeting on 8 December 2020, agreement in principle had been...
Taxing multinationals: what the statistics reveal
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...
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