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Engage early with HMRC to obtain exemption from the uncertain tax treatment rules
Large businesses are encouraged to provide relevant information to HMRC at an earlier stage to gain exemption from notification under the uncertain tax treatment (UTT) rules. This is a key message in the revised draft guidance which is open for...
UK Ring-fencing Review - Update
Last week the panel in charge of leading the review of the UK bank ring-fencing regime (the RFPT Panel) published an update on the progress of the review. While the Panel's final report and recommendations will be published later in the year (the update...
UK Investment Firm Prudential Regime - "fit for purpose"
The new Investment Firm Prudential Regime (IFPR) that applies to MiFID investment firms regulated by the UK Financial Conduct Authority (FCA) came into force on 1 January 2022. These include current firms within scope of the regulator's prudential...
European Commission expresses competition concerns with consumer Internet of Things sector
The European Commission has published its final report in its inquiry into the consumer Internet of Things (IoT) sector, confirming its preliminary concerns (as reported in our previous Lens post). In the words of Executive Vice-President Margrethe...
Biting off more than they can chew? French regulator issues more cookie fines to Big Tech
On the last day of 2021, the French regulator, the Commission Nationale de l'Informatique et des Libertés (CNIL), issued fines to Facebook Ireland Limited, Google LLC and Google Ireland Limited for failure to comply with the French Data Protection Act....
A question of substance – a first look at the EU Commission's "Unshell Proposal"
Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax authorities as well as an increase in substance requirements – have found their way into a new legislative proposal by the...
Meta challenges CMA's first Big Tech prohibition
On 23 December 2021 Meta Platforms, Inc (formerly Facebook, Inc) challenged the CMA's decision ordering it to sell off Giphy, the GIF-sharing search engine acquired by Facebook in May 2020. Meta is challenging the CMA's decision on six grounds, including...
Crypto: Promo Go Slow
What feels several lifetimes ago in the world of crypto, in July 2020, HM Treasury published a consultation on bringing cryptoassets into the UK financial promotion regime. Yesterday, it published the response to that consultation. In a connected move,...
RAP (feat. statutory guidance): ICO releases draft enforcement strategy for consultation
In December 2021, the ICO released its revised draft Regulatory Action Policy (RAP); revised draft Statutory Guidance on Regulatory Action; and draft Statutory Guidance on PECR Powers, proposed to replace the ICO’s existing RAP and statutory guidance. The...
When is VAT due or paid?
The CJEU’s judgment in Case C-156/20 Zipvit v HMRC clarifies that, for the purposes of Article 168(a) of the Principal VAT Directive, VAT is neither “due” nor “paid” (and, therefore, no input tax is recoverable) where the recipient of the supply, the...
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