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Automatic transfer of certain French tax cases to the Public Prosecutor On 27 September, one of the key measures introduced by the recent Anti-Fraud Law (which was adopted by the French Parliament on 23 October 2018) has been confirmed by the French Constitutional Council. This important decision is in response to a request...
Who pays UK corporation tax? Earlier this week, HMRC published their annual corporation tax statistics, and they provide some interesting insights into who is paying the tax. Total CT liabilities increased from £50bn to £55bn from 2016/17 to 2017/18, despite the one per cent fall in...
What can we learn from Starbucks and Fiat? The European Court ruled yesterday that the EU Commission had not been able to demonstrate that the advance pricing agreement between Starbucks and the Dutch tax authority amounted to illegal State aid.  The Starbucks Dutch company concerned was...
Rule of tax law or rule of tax judges? «There is no liberty if the judiciary power be not separated from the legislative and executive» (C.L. de Montesquieu, The Spirit of Laws, Book XI, 6 Of the Constitution of England, 1748). For centuries, the principles of the separation of powers and...
'Technology, Access to Justice and the Rule of Law': a new report from the Law Society Despite the rapid technological changes which have taken place in the past few years, disrupting almost all facets of our lives, there has been a marked decline in access to justice since the 2008 recession. In a report published on 16 September 2019, the...
Where should the holding company be? In any cross-border merger transaction, an early question will often be where the holding company for the merged group should be located.  This is not just a tax question - the location of the business, stock market requirements and practical issues for...
Observations around Tax Certainty Today is the first OECD Tax Certainty Day. We have asked some of our authors for their thoughts on the topic. One of my fellow panellists at last week’s IFA Congress in London made this pertinent observation. In its work on developing a global anti-base...
A new Protocol will significantly amend the U.S.-Spain Tax Treaty On 27 November 2019, the U.S.-Spanish Tax Treaty, which dates back to 1990, will be significantly amended by the entry into force of a new Protocol. In most cases, the Protocol eliminates taxation at source, creating significant savings and consequently...
Google settles its French tax disputes for EUR 1 billion On September 12, 2019, the US tech giant Google agreed to pay close to EUR 1 billion to settle both a criminal investigation for tax fraud by the French Prosecution Office and an ongoing dispute with the French tax authorities focused on the existence of...
ECJ Danish cases: can we have a clear user manual, please? It is more than six months since the ECJ’s decisions in the Danish beneficial ownership cases, but taxpayers and tax practitioners are still trying to get to grips with what the decisions will mean in practice.  There are those who think the consequences...