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Beneficial ownership from a UK perspective Beneficial ownership (or beneficial entitlement) concepts are used across the UK tax code in relation to domestic provisions as well as in the application of double tax treaties. Since the Court of Appeal’s decision in Indofood in 2006, the majority view...
Beneficial ownership from a Portuguese perspective The Portuguese tax authority has started to deny withholding tax refunds (requested by non-resident recipients who had not yet completed the two-year holding period required for the application of the Interest and Royalties Directive by the time the...
Beneficial ownership from a Spanish perspective Since the Danish conduit cases, the Spanish tax authorities have used the beneficial ownership concept to deny the application of withholding tax exemptions, especially where dividends or interest are paid to an entity resident in another EU country but...
IoT cybersecurity regulation picks up pace The regulatory framework for securing IoT devices is attracting the attention of both UK and EU regulators. In the EU, its Member States have recently agreed a common position on the proposed Cyber Resilience Act (which will deal with cybersecurity...
Full steam ahead: China publishes interim generative AI measures New week, new measures: such is the current pace of regulatory change regarding AI, each week can bring major new developments in the regulatory landscape. On 13 July 2023, the Cyberspace Administration of China (CAC) published a set of ‘Interim Measures...
Biden makes new deal with leading AI companies As the AI related headlines keep coming, governments and regulators across the globe are starting to take action. The EU’s AI Act has taken much of the focus to-date, while the UK Government is moving at pace to flesh out its own, pragmatic, regime. But...
Code of Practice on Copyright and Artificial Intelligence – are we in for an endless summer? As work on the UKIPO’s Code of Practice on Copyright and Artificial Intelligence gets underway, the UKIPO has published its Terms of Reference for the technical working group, together with a list of working group members. Whilst these appear to be...
International tax reform: the gift that keeps on giving The OECD published a second set of Administrative Guidance on the Pillar Two GloBE Rules and the GloBE Information Return (and numerous other documents), while the UK released 30 pages of proposed amendments to the legislation implementing the Income...
Recapping Regulation: A big week for fintech It is a good time to check in on the financial regulation lawyer in your life, following a deluge of regulatory updates as the UK sails towards its post-Brexit framework. Here, we recap the updates from the past week that matter to those in the fintech...
Another RETT reform in Germany? A far-reaching reform of the German real estate transfer tax (RETT) rules has been proposed which, if implemented, is intended to apply to transactions that take place after 31 December 2023.  In July 2023, the German Federal Ministry of Finance (BMF)...