12/15/2023 12:03:27 PM Cryptoasset reporting: collecting data on the data economy By Slaughter and May With cryptoassets hitting the news again recently, financial regulators and tax authorities are moving to place a tighter rein on the...
12/4/2023 3:24:02 PM Sunny days ahead for green energy investors: new Spanish tax ruling brightens prospects for RtB greenfield projects in the renewable energy sector By Daniel Alió Euvrard Luis Suárez de Centi A recent binding tax ruling (V2200-23) issued by the Spanish tax authorities introduces a favourable change to the criteria to be met to...
11/24/2023 3:06:58 PM The Scheme for Full Expensing By Ed Milliner Of the business tax measures officially announced as part of the Autumn Statement 2023, one of the more ostentatiously trailed beforehand...
11/24/2023 9:59:38 AM Stamp duty in the Autumn Statement 2023: update on the 1.5% charge and extension of the growth market exemption By Tanja Velling The Budget Resolutions published following the Autumn Statement 2023 give temporary statutory effect to provisions intended to remove the...
11/23/2023 12:13:32 PM R&D Tax in the Autumn Statement 2023: A tale of two regimes By Kasim Mehmood For those, like me, who have been following the ever-changing research and development (R&D) tax relief landscape in the UK over the past...
11/22/2023 6:10:19 PM Autumn Statement 2023: ORIP out - UTPR in By Tanja Velling As trailed on X (previously Twitter), the Chancellor delivered the Autumn Statement on 22 November 2023 with “110 different measures to...
11/8/2023 9:56:45 AM Love, not money, is the basis for all happiness in life … and for tax residence in Italy By Michele Dimonte On 16 October 2023 the Italian Government preliminarily approved a legislative decree to implement a reform regarding international...
11/7/2023 4:12:36 PM Are you an AIF? Are you comparable to a Spanish AIF? If yes, you could be entitled to a limited 1% tax on your Spanish source income By Violeta Pina Carlos Arrieta Martínez Valentín Magraner Bou The 1% income tax treatment, instead of the standard 19% tax, is available to non-Spanish tax resident alternative investment funds...
9/27/2023 1:34:09 PM Where are you on Pillar Two? By Zoe Andrews Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...
9/18/2023 9:36:00 AM Has the UK just abolished its 1.5% stamp duty charge? By Mike Lane Tanja Velling “I see the 1.5% is being removed!” was the subject line of a client e-mail received early last Thursday afternoon in light of HMRC’s...
9/12/2023 10:43:21 AM Can French taxpayers appeal against an administrative decision refusing them a refund of undue tax where the Kühne & Heitz conditions are met? By Yves Rutschmann Ronan Vallerie Amaury Monnet-Vallon In the landmark Kühne & Heitz case, the Court of Justice held that an administrative body is – under certain conditions – obliged to...
9/1/2023 1:18:12 PM Looking at the bigger picture: CGT planning and the purpose test in the reorganisation rules By Tanja Velling If we imagine a Venn diagram of two overlapping circles, A and B, and call the overlapping area C, what can we say about the individual...
8/10/2023 2:43:04 PM No joy for JTI: but whose purposes are unallowable? By Slaughter and May For UK tax practitioners who are feeling bereft after binge-watching the final season of Succession, the ongoing series of “unallowable...
8/2/2023 10:59:50 AM Criminalisation of tax issues in Europe By Stefano Brunello Dormal Yves Rutschmann Jan Adami Teresa Morales +1 more... Show less In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
7/31/2023 9:41:48 AM Purpose tests in anti-abuse or anti-avoidance provisions: perspectives across Europe By Stefano Brunello Dormal Victor Camatta Mees Vergouwen Jan Adami Tanja Velling Marta Pontes Teresa Morales +4 more... Show less In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
7/31/2023 9:41:23 AM Purpose tests in anti-abuse or anti-avoidance provisions in Italy By Stefano Brunello Dormal Umberto Lorenzi There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...