European Tax Blog

12/17/2025 2:45:08 PM

Hotel La Tour Supreme Court decision: no VAT recovery on share sale deal fees

By Zoe Andrews

The Supreme Court in Hotel La Tour has unanimously rejected the taxpayer’s appeal and determined that the input tax on deal fees...

11/26/2025 7:26:44 PM

Smorgasbord not showstopper: the UK Budget 2025

By Nadia Hourihan Patrick Follan

The November 2025 budget is here at last. During the months of speculation in the run-up to the big day, two possible futures emerged: a...

11/26/2025 6:34:00 PM

Autumn Budget 2025: UK Listing Relief for Stamp Duty Reserve Tax

By Kasim Mehmood

Amidst the broader UK stamp taxes on shares modernisation efforts (discussed here and here), today in her Autumn Budget 2025, the...

11/25/2025 3:52:01 PM

The proposed Italian taxation of portfolio dividends and the principle of non-(reverse) discrimination

By Michele Dimonte

The proposed reform of the taxation of portfolio dividends is a seemingly marginal adjustment to the Italian tax system, but akin to...

11/18/2025 10:47:55 AM

2024 OECD MAP statistics: Key trends in MAP and APAS as Ireland recognised as most improved jurisdiction for APAS

By Trevor Glavey

Introduction Ireland is committed to implementing OECD BEPS Action 14 for effective dispute prevention and resolution. As part of this...

10/23/2025 10:08:08 AM

Australian Court proceedings stayed in Oracle case to allow for Irish MAP

By Angelina Lagana Joseph Tranzillo

In its dispute concerning whether distribution payments were “royalties” for Australian withholding tax purposes, the Full Court of the...

10/2/2025 9:00:59 AM

Civil and criminal investigations by HMRC: Drawing the line

By Sarah Osprey Patrick Follan

So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on...

9/30/2025 12:46:13 PM

French Digital Services Tax: a French Tribunal rules in favor of the taxpayer on the concept of economically independent services from the taxable digital service

By Victor Camatta Claire Chabredier

The Administrative Tribunal of Cergy-Pontoise issued the first decision on the merits concerning the application of the French Digital...

9/30/2025 10:45:45 AM

Appealing a UK tax case beyond the First-tier Tribunal: five points to consider

By Sarah Osprey Amy Motherwell

With HMRC statistics showing that HMRC was successful (at least in part) in 93% of First-tier Tribunal (FTT) tax cases in 2024/25, many...

9/25/2025 9:07:01 AM

What happens when you take a UK tax dispute to the First-tier Tribunal?

By Sarah Osprey Jamshed Bilimoria Michelle Blake

The First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The...

9/23/2025 9:17:21 AM

First steps in challenging a tax assessment in the UK

By Sarah Osprey Jamshed Bilimoria Michelle Blake +1 more...

Previous posts in our series on tax disputes in the UK considered how an HMRC enquiry is likely to proceed and be concluded. In this and...

9/18/2025 9:30:11 AM

Can you rely on a tax treaty to progress an HMRC enquiry?

By Sarah Osprey Zoe Andrews Tanja Velling

If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what...

9/16/2025 1:43:59 PM

Bringing an HMRC enquiry to conclusion

By Sarah Osprey Alex Sim Nadia Hourihan

HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many...

9/11/2025 2:00:36 PM

Supreme Court in Prudential Assurance clarifies interaction of VAT grouping and time of supply rules

By Zoe Andrews

Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for...

9/11/2025 9:00:00 AM

Privilege in UK tax disputes: Five questions answered

By Sarah Osprey Zoe Andrews Tanja Velling

HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask...

9/10/2025 3:33:41 PM

Spain’s National Court recognises non-EU taxpayers’ right to be taxed on a net basis, by deducting expenses against their Spanish source income

By Guillermo Canalejo Isabel Desviat

In a landmark decision, Spain’s National Court (Audiencia Nacional) has applied CJEU case law on the free movement of capital to conclude...