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,...
12/16/2022 2:55:42 PM Provisional agreement reached on the European Union's Carbon Border Adjustment Mechanism By Helena Campbell Aaron Wu The Council of the European Union issued a press release on Tuesday, stating that negotiators representing the European Parliament and...
11/23/2022 10:26:50 AM Interpreting tax treaties - Dutch Supreme Court clarifies relevance of later OECD commentaries By Mees Vergouwen In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage...
10/26/2022 9:29:14 AM Finland fills the gaps in tax legislation - impact on non-resident real estate investors By Einari Karhu With the parliamentary elections looming in a few months, the Finnish Government has stepped on the gas pedal to ensure it can enact tax...
7/29/2022 9:59:42 AM BlackRock revisited: what is the purpose of the “unallowable purpose” rule? By Slaughter and May That might sound like a strange question, but it lurks just beneath the surface of the Upper Tribunal’s keenly-awaited decision in...
6/27/2022 8:44:13 AM Greening Imports: UK Government to consult on a unilateral CBAM By Slaughter and May It's been an interesting month so far in the world of climate taxes. For a brief moment it looked as though pens were down on the...
6/8/2022 1:47:47 PM EU CFC State aid decision: the death of Cadbury Schweppes? By Mike Lane The General Court released its decision in the UK's and ITV's appeals against the Commission's decision that the UK's CFC finance company...
6/7/2022 2:16:18 PM Ok, I was wrong (or when tax doesn't follow form but in my view should have) By Mike Lane A little over a year ago, I wrote a post called "The cautionary tale of Mr Bostan Khan". It was prompted by the Court of Appeal decision...
6/7/2022 10:15:14 AM Net Zero: can tax help guide a unified approach? By Slaughter and May It is perhaps trite to say that tax can be used as the proverbial carrot and stick alike - or simply as a revenue raiser. It also goes...
5/31/2022 8:45:10 AM Taxing oil and gas: a new tax and an investment incentive By Ed Milliner Zoe Andrews The introduction of the “Energy Profits Levy” announced by the UK Chancellor on 26 May 2022 to take effect from the same date would...
5/30/2022 2:56:06 PM “Reference” value: the new Spanish “market” value for real estate transactions By Cristina Puerta Since 1 January 2022, taxpayers in Spain have had to pay tax on the “reference value” of their real estate acquisitions, which is a value...
5/18/2022 1:24:16 PM DEBRA: A deleveraging allowance to reduce the debt-equity bias By Tanja Velling If one were to regard the European Commission’s Directive proposal to tackle the debt-equity bias in the tax system as the fruit of a...
4/14/2022 1:18:24 PM Third party access to documents in the courts and tribunals By Tom Windsor Taxpayers bringing appeals against HMRC in the First-tier Tribunal (Tax Chamber) (the FTT) are rightly concerned to mitigate the risk...
4/12/2022 2:13:25 PM Certain provisions of the administrative guidelines on the 3% French DST judged as incorrectly interpreting the law By Yves Rutschmann Victor Camatta In 2019, a French Digital Services Tax (DST) was enacted in order to subject to a 3% tax two categories of services provided in France:...
4/4/2022 11:15:02 AM CJEU rules that the Portuguese tax regime applicable to UCIs restricts the free movement of capital By António Castro Caldas Gerard Everaert In a decision that will unlock a number of pending cases and encourage EU (and third country) UCIs to apply for a refund of Portuguese...