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UK CFC rules and EU State aid: an update A lot has happened since April when the European Commission published its full decision on the UK’s CFC rules explaining why it considers that the CFC rules for exempting non-trading finance profits constituted State aid to the extent that the relevant...
What should your non-tax colleagues know about DAC 6? DAC 6, the 2018 amendment to the Directive on Administrative Cooperation, is top of many tax adviser's worry list.  Tax advisers involved in international transactions have become intermediaries. And those of us who are in the EU will have to report to...
Update on German Real Estate Transfer Tax (RETT) Reform What is it all about?  The public perception, pushed by politicians and the press, is that the German real estate transfer tax (RETT) applies unfairly: while every transfer of real estate itself is subject to RETT, it is assumed that the shares in real...
Dawn raids and data dumps: handling the practical realities of tax disputes In the past, many tax disputes were run as technical debates, where the parties (largely) agreed the facts, the court had little contested evidence to consider, and the focus was on the precise interpretation of the law.  That is no longer the case – and...
73rd International Fiscal Association (IFA) Congress in London I post this blog on my way to the Women of IFA Network (WIN) Meet & Greet Reception, the first of many WIN activities taking place between today and Thursday during the 73rd IFA Congress in London. On behalf of Slaughter and May, I warmly welcome all...
Events Team innovation is a recipe for success Innovation comes in many forms, and by stirring up the Firm’s flagship client-facing event, our Events team have secured a double award win.  The In-House Corporate Events, (ICE) awards reward the best and most innovative achievements of in-house...
DSTs and State aid: the Hungarian advertising tax State aid case Earlier this year, Zoe Andrews wrote that the General Court's decision in the Polish retail tax State aid case paves the way for digital services taxes.  Yesterday, the notice of the General Court's judgment in a similar Hungarian State aid case was...
Music to regulators' ears? Antitrust, RPM, and AI This month, the UK Competition and Markets Authority (CMA) fined Casio Electronics (the UK-based unit of Casio Computer) GBP 3.7 million for its actions in dictating minimum prices to online retailers of its electronic pianos and keyboards.  Casio also...
Taxpayers, tax authorities and tech "Making Tax Digital"  stands for a drive by the UK tax authority, HMRC, to move to digital records and returns. The stated aim is to make tax compliance easier, with the by-product of narrowing the tax gap through online record keeping. That tax...
Proposed ATAD 2 hybrid rules in the Netherlands will have a far-reaching impact On 2 July 2019, the Dutch government published a bill implementing the second EU anti-tax avoidance directive (ATAD 2). Once enacted, the bill will neutralise certain hybrid mismatch arrangements, which would otherwise result in double non-taxation. It is...