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Co-opting digital companies into tax law enforcement Today, The Times reported that some 38,000 online sellers registered for VAT in the UK in 2017-18, compared to 29,000 in the previous year and just 5,000 three years earlier. Why this increase? Since March 2018, UK legislation requires operators of online...
Taxing the digital economy: impact assessments will help identify winners and losers The G20 has endorsed the OECD's work programme consisting of the two-pillar approach which was the subject of Tanja Velling's recent post.  The G20’s communiqué shows that there is political support at the highest level for this project and it is full...
How low is low taxation? – The reform of the German CFC rules Germany's controlled foreign corporation rules (CFC rules, Hinzurechnungsbesteuerung) date back to 1974 and have never really been modernized. Low taxed income, for instance, is understood as income subject to a corporate income tax rate of 25%. In the...
The tax residence of companies. A matter of fact, or a fact that does not matter? In her recent post, Tanja Velling highlights some of the uncertainties in the UK around the tax residence of a company. This is not just a UK issue, as it is far from being clear in many other countries. For companies not belonging to a group, agreeing on...
New Residents First! Italy is facing a dramatic outflow of “human capital”. According to Eurostat, only Romania and Poland pips Italy to the post in terms of emigration to other EU countries. But back to Italy: 30% of those who leave have a university degree (the rest are...
All clear on tax residence? The First-tier Tax Tribunal's unhelpful decision in the Development Securities case has been reversed by an Upper Tribunal decision which was published today and (at least for now) provides comfort that a lot more is required than a subsidiary's...
Decision time for the UK Government on the CFC State aid challenge The time limit for the UK to appeal the EU’s State aid decision in relation to the UK’s CFC regime is fast approaching, and we still do not know whether the UK itself will appeal. This is a political decision that needs to be made by the UK Government,...
CMA invites views on digital mergers while French shelve plans for ex-post review in favour of EU approach At a speech in Paris on Monday, CMA Chief Andrea Coscelli outlined the findings of the Lear report - a retrospective look at how and on what basis the CMA's predecessor institutions analysed (and cleared) past digital mergers. Coscelli also announced a...
Dutch interest free loan structures at risk after Huhtamäki? The EC has decided to open an in-depth investigation into whether Luxembourg may have granted illegal state aid to the Huhatmäki group. Because the structure under review can be replicated in exactly the same form in the Netherlands, and in fact has been...
Reviewing robots: governance over AI Earlier this week, James Proudman, Executive Director of UK Deposit Takers Supervision at the PRA, gave a speech on the governance of artificial intelligence in financial institutions. The speech called out a number of important things which the boards of...