What's (not) changing in pensions tax?
The proportion of people in the UK aged 65 or over is projected to reach almost a quarter by 2037, and engagement with workplace pensions...
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COVID-19 impact on Spanish Tax Residence for Individuals: the controversial position adopted by the Spanish Tax Authorities
Disregarding the spirit of the OECD guidance on how to deal with COVID-19 exceptional circumstances, the Spanish tax authorities have...
Dutch courts embrace Danish conduit cases
Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to...
Rule of law vs Rule of judges – 1:0
In the tug of war between the Italian Parliament and Supreme Court in respect of the indirect tax treatment of indirect business transfers (
Loosening up access to information
The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from...
First Spanish rules on the taxation of carried interest
For the first time, the Basque Country and Navarre have enacted regulations on the Personal Income Tax treatment of carried...
Tax residence post-MLI
Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD)...
Back to the future...
When I first qualified into tax, UK-UK transfer pricing was not a thing. A UK company could lend money to a fellow UK group company...
A simpler and more modern tax environment sounds good – but what about tax competition?
The Apple case is seen as raising the (very) hot topic of how a multinational group like Apple should be taxed in a modern, digital...
Three little words...
We all know the difference three little words can make. But in the case of VAT, those three little words turn out not to be "I love...
Is it exempt or can we apportion?
According to a German saying, “before the court and at sea, one is in God's hands.” The CJEU’s decision in Blackrock shows that, for...
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