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How to get someone to pay for your wall Ever since my husband got an iPhone, I have become 'quite' familiar with the yellow BBC Sports banner at the top of the screen, because he is almost always reading sports news, and usually about one sport in particular, football.  But starting this season...
Silicon Valley - 'A Sea of Dudes'? 'Exposing Data Bias in a World Designed by Men' It is broadly accepted that the tech sector lags behind others in relation to diversity, inclusion and gender equality. In her recently published book 'Invisible Women: Exposing Data Bias in a World Designed by Men', Caroline Criado Perez demonstrates why...
A step towards HMRC's understanding of digital tech businesses From January to April 2017, Ipsos MORI conducted qualitative research in the form of 50 in-depth interviews with UK digital tech businesses on behalf of the UK's tax authority, HMRC.  Today, the report was published. It aims to provide exploratory...
Finnish reform to dividend withholding tax – is it really a risk worth taking? Finnish withholding tax (WHT) on dividends paid by Finnish listed corporations will change significantly from 2021. A criticized reform will abolish the current so-called ‘simplified procedure’ for nominee-registered shares that has secured a lower 15%...
Biscuits, Brexit, and big data Britain's favourite biscuit is the McVitie's milk chocolate digestive.  Britain's favourite ice lollies are Magnum ice creams.  And most memorably, the UK will decide to remain in the EU.  All of these are the result of polls of individuals conducted by...
What are your losses worth? Subject to a £5m deduction allowance, UK corporation tax payers may use carried-forward income losses against up to only 50% of their profits. In July, the government has published draft legislation to extend this restriction from 1 April 2020 to...
When a notice isn't a notice... English law governed acquisition agreements commonly require the purchaser to notify the seller of any claim against the target - for example by a tax authority - which could give rise to a claim by the purchaser against the seller - for example under a...
The French 3% Digital Services Tax comes into effect The Bill introducing the French Digital Services Tax (the “French DST”) presented by the French Government on 6 March 2019 and subsequently amended by the National Assembly and the Senate, was formally enacted on 24 July 2019 and then published on 25 July...
UK implementation of DAC 6 The draft regulations to implement EU Directive 2018/822 (DAC 6) in the UK have been published alongside a consultation document. HMRC requests responses by 11 October 2019. Legislation must then be introduced by 31 December 2019 and will be accompanied...
Commission’s decision to investigate Nike tax rulings explained The European Commission recently published its decision to initiate a State aid investigation into Dutch tax rulings relating to Nike. The Nike case focuses on EMEA structures (including well-known CV/BV structures) where Dutch group companies with...