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The ORIP rules: intangible property held in the Crown Dependencies It may be tempting to think that, following the renegotiation of the double tax treaties (DTTs) between the UK and the Crown Dependencies (Guernsey, the Isle of Man and Jersey), entities resident in one of them would fall outside the scope of the UK's...
US Treasury Department Loosens “Earnings Stripping” Rules The latest salvo in a years-long struggle to administer US “earnings stripping” rules took another turn on 31 October, when the US Treasury Department announced that it would loosen rules designed to limit the practice. “Earnings stripping” or “interest...
Filing tax returns becomes a high risk occupation In the 2020 Finance Bill, the Italian Government announced its intention to combat tax evasion, thought to cost more than 100 billion Euros a year to a national budget in constant deficit.   In these times of blaring proclamations, politicians are...
Tax on cryptoassets: HMRC’s latest guidance for business In December 2018, I wrote a blog about HMRC’s guidance for individuals on the taxation of cryptoassets. HMRC has, nearly a year later, followed up with guidance for business on the tax treatment of exchange tokens, such as bitcoin. The guidance notes that...
Dutch based in-house tax departments can be intermediaries under DAC6 As the 31 December 2019 deadline for the implementation of DAC6 into the national legislation of EU Member States draws closer, legislators across the EU little by little shed more light on the scope of application of DAC6.  In the most recent explanatory...
Discriminatory tax treatment of foreign Real Estate Investment Funds (REIFs) Are closed-ended Italian REIFs and open-ended REIFs in a comparable position for Italian indirect tax purposes? The ECJ is set to address this question within months (C-479/19). The request for a preliminary ruling was referred by the Italian Supreme...
Putting the ML into AML The FCA and Bank of England have recently published the findings of their first ever survey of the use of machine learning (ML) in financial services firms. The conclusions from the survey are that there has been significant uptake and deployment of ML in...
Conforming interpretation revisited The UK’s First-tier Tax Tribunal's decision in Panayi has been published. Whilst the case was reminiscent of Gallaher  (previously discussed by Sara Luder), the Judge reached what looks like an opposing conclusion.  Panayi  concerned a capital gains tax...
Freedom to move capital to (or from) overseas territories Transfers between the UK and Jersey are, according to the UK Supreme Court, within the scope of the freedom of movement of capital under what is now article 63 of the Treaty on the Functioning of the European Union.  Routier v HMRC concerned a potential...
The General Court’s Starbucks and FIAT rulings: what’s new and what’s not The long-awaited judgments by the General Court of the EU – on whether unlawful stated aid purportedly granted by the Netherlands and Luxembourg to Starbucks and FIAT – have received much public attention. And with good reason. While applying state aid...