5/27/2020 12:00:00 AM How will COVID-19 affect the future of environmental taxes? By Slaughter and May Whilst the impact of COVID-19 on the environmental taxes agenda is yet to be fully understood, it would seem prudent for businesses to...
5/26/2020 9:19:07 AM How many hammers are needed to crack a nut? By Tanja Velling The ‘cum-ex scandal’ being the nut in question here. After a consortium of journalists uncovered schemes generating multiple refunds of...
5/21/2020 3:45:03 PM How far does the fiction of a deeming provision extend? By Zoe Andrews Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC....
5/15/2020 12:05:03 PM Dutch tax treatment of intra-group debt guarantees at odds with OECD guidance By Maarten van der Weijden The paragraph of the OECD transfer pricing guidance on financial transactions dealing with parent guarantees is, in my view, incompatible...
5/15/2020 8:20:01 AM No fixed establishment through parent-subsidiary relationship By Tanja Velling Or at least not automatically. A company established outside the EU does not have a fixed establishment for VAT purposes in an EU Member...
5/14/2020 12:00:00 AM Partnership taxation: still a work in progress? By Mike Lane Given the general view of partnership taxation – “they’re just transparent, right?” – it is somewhat surprising that how a partnership...
5/7/2020 1:21:23 PM When is a resident not a resident? By Mike Lane It sounds like a bad joke, befitting of a tax lawyer in lockdown, but is really just a reminder to check the small print in double tax...
5/7/2020 11:16:27 AM Trust recognised as a “person”, but fails to get treaty benefits By Andrea Manzitti A UK trust is a “person” for the purposes of the Italy-UK double tax treaty - that is the good news coming out of a recent Italian...