3/29/2021 4:02:25 PM UK and other non-EU taxpayers: beware of the Spanish VAT use and enjoyment rule! By Alberto Linares Following a previous post on the Spanish VAT rules for UK taxpayers after Brexit, this post addresses the so-called use and enjoyment VAT...
3/23/2021 4:53:03 PM Tax Day! By Tanja Velling The UK Government has, in its own words, published "more than 30 tax updates, consultations and documents in a move to strengthen...
3/17/2021 2:22:03 PM Is DAC6 a proportional measure? By Gloria Marín There is a question whether DAC6 might violate the principle of proportionality in Article 5(4) of the TEU. This principle requires that...
3/17/2021 10:31:46 AM Highlights of the new Spanish wealth taxation criteria for non-resident high net-worth individuals By Javier Arregui Alex Pié The Spanish courts and tax authorities have recently issued several judgments and rulings of potential interest to high net-worth...
3/15/2021 12:00:00 AM Avoiding double DAC6 reporting: is the hierarchy in Article 8ab(3) of the DAC compatible with the freedom of establishment? By Gloria Marín The priority given, for the purpose of DAC6 reporting, to the Member State of residence over the Member State in which an intermediary...
3/12/2021 9:01:41 AM Penalties for failure to make a DAC6 report and the right to a fair trial By Gloria Marín Authorities may not impose penalties on individuals for refusing to provide information that may prove their criminal liability or...
3/12/2021 12:00:00 AM The difficulties with deeming - VAT, groups and time of supply By Ed Milliner Clashes between deeming provisions in a complex tax code inevitably give rise to tricky technical questions and, quite often, litigation....
3/10/2021 12:00:00 AM Does some Member States' implementation of the legal professional privilege exemption from DAC6 reporting infringe higher-ranking Union standards? By Gloria Marín The way in which some Member States have implemented DAC6 raises legitimate concerns on its validity and compatibility with...
3/9/2021 11:31:45 AM Income tax free securitisation of real estate in Italy By Michele Dimonte Andrea Manzitti In a recent ruling (No. 132 of 3 March 2021) the Revenue Agency has confirmed that SPVs used to secure proceeds from the direct ownership...
3/8/2021 9:57:44 AM DAC6 and legal professional privilege - request for a preliminary ruling By Gloria Marín On 21 December 2020, the Belgian Constitutional Court (Grondwettelijk Hof) requested a preliminary ruling from the CJEU on the DAC 6...
3/4/2021 12:00:00 AM The corporation tax rise in pictures... By Mike Lane For those who prefer to think in pictures, this chart from the OBR's 2018 report "Why have onshore CT receipts performed so well since...
3/3/2021 12:00:00 AM Has the Chancellor really just announced a UK corporation tax rise of over 30%? By Mike Lane TLDR – yes, it seems he has. The Chancellor is still trumpeting the rate as the lowest in the G7, even after the rise. But for those...
3/3/2021 12:00:00 AM UK’s March 2021 Budget: Spend now – pay later By Tanja Velling The UK’s headline corporation tax rate is set to rise to 25% from April 2023 (with a commensurate increase in the diverted profits tax...
3/2/2021 12:00:00 AM Germany and foreign-to-foreign IP transactions: the next act By Verena Klosterkemper In 2020, many foreign companies were taken by surprise when they learnt that they might have fallen within the scope of German...