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Cookie catch-up: What you need to know about the CNIL’s Google and Shein fines (and other summer developments) At the start of September, the French data protection authority (the CNIL) issued record breaking cookie penalties against Google (€325 million) and online fashion retailer Shein (€150 million). With the UK’s cookie penalties set to increase at the end of...
Bringing an HMRC enquiry to conclusion HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many years, with numerous requests for information. Compliance costs can mount and potentially awkward disclosures may need...
As the Data Act becomes applicable, what do you need to know? The EU’s flagship Data Act starts to apply today (12 September), marking a new phase for data sharing in the EU. The Data Act, an EU regulation (2023/2854), promises to enhance the EU’s data economy and facilitate data-driven innovation by increasing the...
Supreme Court in Prudential Assurance clarifies interaction of VAT grouping and time of supply rules Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for the services comprises a quarterly management fee and success fees. The success fees depend on investment performance...
Privilege in UK tax disputes: Five questions answered HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask for them. Careful thought is required when assessing if a document really is privileged (and so can be withheld) and,...
Spain’s National Court recognises non-EU taxpayers’ right to be taxed on a net basis, by deducting expenses against their Spanish source income In a landmark decision, Spain’s National Court (Audiencia Nacional) has applied CJEU case law on the free movement of capital to conclude that non-EU/EEA taxpayers subject to the Non-Resident Income Tax (NRIT) are entitled to deduct expenses directly...
Zalando loses its challenge against DSA VLOP designation On 3 September 2025, the General Court of the European Union delivered the first major judicial interpretation of the DSA in its dismissal of Zalando’s challenge against its designation as a “very large online platform” (“VLOP”) under the EU’s Digital...
German Federal Fiscal Court rules against double RETT on share deals 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 real estate transfer tax (RETT) in share deals, where the contractual obligation transaction (signing) and the actual...
How to respond to information requests from HMRC A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes in the UK, we discussed what to look out for when HMRC open an enquiry – and noted that enquiries often go on for years...
What to do when HMRC open an enquiry Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of HMRC enquiries – which will often last for years, given that there is no statutory time limit for HMRC to complete an...