European Tax

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...

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

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

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

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

In a decision dated 9 July 2025, the German Federal Fiscal Court (docket no. II B 13/25) addressed the issue of a double assessment of...

A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes...

Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of...

Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the...

In a much anticipated, eagerly awaited decision, the Australian High Court today, in a 4/3 majority judgment in Commissioner of Taxation...

Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in...

Dividends received by Italian financial intermediaries (including banks) from their subsidiaries are subject to Italy’s regional tax on...

Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...

In October 2024, the UK Government announced as part of the budget that from 6 April 2027, “inherited pensions [will be brought] into...

The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation....

The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...