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National data strategy – Government to lead by example… The Government has published the UK’s National Data Strategy for consultation, building on its manifesto pledge to improve data use in government, and looking at ways to help businesses of all sizes benefit from the ‘data revolution’. It forms part of the...
“Prepare to jump to lightspeed!” – hyperspace, hyperlinks and the Copyright Directive The mention of Star Wars and copyright together often conjures to mind the well-known Stormtrooper helmet case.  But that may be about to change now that AG Szpunar has opened his recent Opinion in VG Bild-Kunst v Stiftung Preußischer Kulturbesitz (Case...
Cum/ex schemes: ESMA recommendations The European Securities and Markets Authority (ESMA) has recommended legislative change to enable National Competent Authorities (NCAs) to share information with tax authorities, but abandoned proposals to enhance NCAs’ supervisory powers to tackle...
UK-Japan trade agreement – what are the initial takeaways? In September, UK Trade Secretary Liz Truss confirmed an agreement with Toshimitsu Motegi, the Japanese Foreign Minister, in the UK’s first major post-Brexit trade deal – which could potentially impact British and Japanese companies when eventually...
Cyber insurance - the questions you should ask The UK National Cyber Security Centre (NCSC) published some guidance this summer for organisations of all sizes who are considering purchasing cyber insurance. The guidance is not intended to be a buyers guide to insurance – rather to enable organisations...
The AI and IP conundrum: UKIPO joins the debate On 7 September, the UKIPO put out a call for views in order to better understand the implications of AI on IP policy, all in the interests of furthering its mission for the “UK to remain at the forefront of the AI and data revolution ”. Engaging in the...
Colombian beneficial ownership concept: Unsolved questions The 2019 Colombian tax reform introduced a new definition of beneficial owner for tax purposes. But the result may be an increase in uncertainty. The definition is overbroad, meaning that a significant volume of additional information may need to be...
Highlights from the 2021 Dutch Budget The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate taxes are concerned, will generally result in an increase of the tax burden on multinational businesses.  The 2021...
Spanish courts adhere to Danish conduit cases When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court (Tribunal Económico-Administrativo Central), a non-judicial and appeal body that forms part of the Spanish Tax Authority...
Buyer beware! Indemnity payments under a share purchase agreement are taxable in the hands of the purchaser, irrespective of their accounting treatment. This is what the Italian Supreme Court held in its decision no. 17011 of 13 August 2020, highlighting the importance...