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Non-Spanish resident pension funds are entitled to the refund of withholding tax on dividends paid by Spanish resident companies A 22 December 2020 ruling from the Spanish Supreme Court (the Ruling) has confirmed that taxing non-Spanish resident pension funds on dividends paid by Spanish-resident companies is contrary to the free movement of capital within the EU. Spanish...
Judge raises the stakes: domain names are intangible property Business.com for $345m in 2007. Lasvegas.com for $90m in 2005. Carinsurance.com for $49.7m in 2010. Given the eye watering sums of money paid for some domain names, it is unsurprising that their proprietary (or otherwise) status has been put under the...
Driving AI development: new UK AI roadmap released On 6 January 2021 the UK Government published an independent report on AI carried out by the AI Council (an independent expert committee set up to advise UK Government and ‘provide high-level leadership of the AI ecosystem’). The report contains 16...
Can you help shape the NCSC's new cyber tookit? The National Cyber Security Centre (NCSC) is updating its Cyber Security Toolkit for Boards, and is seeking feedback from board members and non-executive directors from large organisations, asking them to share their experiences to help shape those...
Revised OECD tax treaty guidance as “temporary” COVID-19 travel restrictions continue to impact business operations The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on questions around the creation of permanent establishments and changes in tax residence as the guidance issued in April 2020....
President Biden’s tax proposals On January 20, 2021, Joseph R. Biden, Jr., took office as the US President.  As Washington’s focus now turns to policy-making, there are serious questions about the future US tax system and whether and to what extent the dramatic policy changes of former...
Is your joint copyright work purple or red/blue? ‘Two heads are better than one’ goes the old saying. Is this always right? It is true that collaboration can foster creativity and a better overall output. However, very often such collaborations later lead to painful copyright ownership disputes. This...
What the deal means for financial services: No change for now The Brexit trade deal lays down the details of the future relationship between the UK and the EU. The main document is the UK-EU Trade and Cooperation Agreement (TCA) which (at the time of writing) is in force provisionally, with ratification to follow ....
German taxation of non-resident license and sale of IP transactions: The struggle continues In 2020, many foreign companies were taken by surprise when they learnt that they might have fallen within the scope of German non-resident taxation with respect to past license and IP sale transactions, even where only non-German parties were involved in...
Ireland's Corporation Tax Roadmap: Overview of January 2021 Update The Irish Minister for Finance, Paschal Donohue, recently published an update to Ireland's Corporation Tax Roadmap (Roadmap). The Roadmap builds on the September 2018 publication and provides stakeholders with an overview of the actions Ireland has taken...