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Are regulators ready for blockchain? Your weekly grocery shopping, high street fashion, designer goods, and bottles of whisky. These are just some of the many products and markets that have employed blockchain technology to manage supply chains, track goods, prevent counterfeiting, increase...
Member of management board can constitute a German taxable presence of a foreign company In a decision dated 23 October 2018 (I R 54/16), but only published on 17 April 2019 the German Federal Fiscal Court (Bundesfinanzhof – “BFH”) held that the managing director of a foreign company can qualify as a German permanent representative within the...
Collaborate: introducing our first cohort We are delighted to announce the first cohort of legal tech developers for Slaughter and May Collaborate, our new legal tech programme. The six businesses, selected by the Collaborate team alongside the programme’s client and expert panels, were chosen...
Repatriation of German-source profits reloaded? Pretty much any German inbound-investment has to consider how profits can be extracted in the most tax-efficient manner. In principle, dividend distributions carry a 25% German withholding tax (plus the solidarity surcharge of 5.5% thereon). German...
ECJ beneficial ownership cases: the end of the Dutch safe harbor rules in sight? Two ECJ rulings of 26 February 2019 cast doubt on whether safe harbour rules applied by the Netherlands are compliant with EU law.  Under these safe harbour rules, an abuse of EU law is deemed not to exist, and consequently benefits under the Interest and...
EU State aid decision on UK CFC rules The full decision in the EU State aid investigation into the UK CFC rules for non-trading finance profits (“NTFP”) has now been published.  In summary, whilst the Commission accepted that NTFP might raise a higher risk of artificial diversion of profit,...
Digital Services Tax in Spain - the world inside-out? With the OECD issuing its February 2019 public consultation, in which a consensus-based and long-term solution for the taxation of the “digital economy” begins to be sought, the Spanish Government seems to be adamant on the potential introduction of a...
UK tax free cross-border transfers In the recent case of Gallaher, the UK’s First-tier Tax Tribunal reached a surprising conclusion on the UK’s intra-group transfer regime. Section 171 TCGA allows assets to be transferred within a tax group on a “no gain/no loss basis”, so long as the...
International tax reform: marketing intangibles proposal attracts support The "marketing intangibles" proposal has emerged from the OECD's public consultation discussions as the most likely of the OECD's proposals to achieve a consensus from the (now 129) countries that are committed to finding a global solution to the...
The ICO is dead, long live the ICO Extract from the winning essay in a competition for young lawyers jointly sponsored by the Banking Law Committee and Securities Law Committee. Abstract Cryptocurrencies. Tokens. ICOs. The buzzwords of the moment. But what exactly are they and what is...