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The Subsidy Control Bill - What you need to know about the UK's proposed new subsidy control regime Following an 8 week consultation on its initial proposals earlier this year, the UK Government has published its response to that consultation together with the much-anticipated Subsidy Control Bill setting out the UK's new subsidy control regime.  As...
Plenty more phish in the sea? Cyber risks for SMEs in the supply chain 57% of small and medium-sized enterprises believe they would go out of business from a serious cyber attack, according to a new report by ENISA (the EU’s agency for cybersecurity). The report included a survey of SMEs in the EU, and highlighted that...
Spanish National Court follows CJEU in placing burden of proving abuse on Spanish tax authorities In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish tax authorities and that the Spanish anti-abuse rule infringes European Union law. The ruling represents a turning...
Exit tax: holding companies may not qualify for Italian participation exemption on migration The Italian Tax Authority confirmed that the participation exemption does not apply to shareholdings that are transferred abroad as part of a going concern (Principle of Law 10/2021). It follows that the participation exemption should be unavailable to...
UK announces post-Brexit trade deal with Australia On 15 June 2021, Boris Johnson announced that the UK had agreed the broad terms of a free trade deal with Australia following a meeting with the Australian Prime Minister, Scott Morrison, with an “Agreement in Principle” expected to be published in the...
ECJ Lexel AB decision casts a shadow over Dutch interest limitation provision The decision of the European Court of Justice in the Lexel AB case raises questions whether the valid business reason exception of article 10a of the 1969 Dutch corporate tax act (CTA), an interest deduction limitation provision, is partly incompatible...
Stamp duty goes officially online - finally! HMRC's press release heralds the decommissioning of the stamp duty press machines as the "end of an era" as the 300-year old process of manually stamping documents to evidence that the required transfer tax has been paid is (officially) going digital from...
Is the G7’s agreement on international tax reform really “seismic”, or is it too soon to tell? Before the G7 Finance Ministers’ communiqué of 5 June announcing an agreement in principle (which was endorsed by the G7 leaders according to their communiqué of 13 June), the biggest news in international tax had been a renewed engagement of the US with...
Is the G7’s agreement on international tax reform really “seismic”, or is it too soon to tell? Before the G7 Finance Ministers’ communiqué of 5 June announcing an agreement in principle (which was endorsed by the G7 leaders according to their communiqué of 13 June), the biggest news in international tax had been a renewed engagement of the US with...
Public CbCR to be implemented in the EU Public country-by-country reporting is set to be implemented across the EU (including for non-EU headquartered groups) by early 2023 to take effect, at the latest, for the first financial year starting on or after early 2024. On Monday, 14 June 2021, the...