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Lessons learned from JTI and other recent unallowable purpose cases The main lesson to be learned is that it all depends on the specific facts and how they are presented to the fact-finding tribunal! JTI is the third unallowable purpose case decided by the UK Court of Appeal this year, the previous two being BlackRock and... The generation game: New EU guidelines published on generative AI and data protection On 3 June, the European Data Protection Supervisor (EDPS) published guidelines on navigating the relationship between generative AI (GenAI) and data protection. While the EDPS’s guidelines are directed at EU institutions rather than businesses, they conta... Change: Labour Party Manifesto 2024 Latest polling figures for the UK’s general election on 4 July continue to indicate a change in government as Labour, the main opposition party, enjoys a c. 20 percentage point lead over the Conservative Party which has governed the UK since 2010. What mi... ECJ lends a helping hand to non-established persons seeking VAT refund According to the decision of the Court of Justice of the European Union of 16 May 2024 (C-746/22), the Hungarian rule that does not allow foreign taxpayers in VAT refund cases to submit their documents even in the appeal procedure is contrary to EU law. W... The U.S. 1% excise tax on stock repurchases may apply to share buybacks made by foreign issuers more often than they think Beginning in 2023, publicly-traded U.S. corporations are subject to a 1% excise tax on the fair market value of the stock repurchases made during the taxable year. The enacting statute also applies the excise tax when a U.S. company repurchases stock of i... Good news for secondary debt markets in interest withholding tax case before UK Upper Tribunal HMRC v Burlington Loan Management DAC is an important decision for the smooth running of secondary debt markets. It is also a helpful precedent for tax authorities, taxpayers and tax advisers alike as they spend more time in the future considering when an... VAT recovery on share sales: no special rule for fundraising transactions The UK Court of Appeal’s decision in Hotel La Tour has dashed taxpayers’ hopes of being more readily able to recover VAT paid on deal fees in respect of share sales. It is possible that the taxpayer may seek to appeal to the Supreme Court (after all, the ... Tech companies to see digital regulation come to the UK More than a year after its first reading in the House of Commons, the Digital Markets, Competition and Consumers Act 2024 received Royal Assent last Friday - one of a handful of bills to be passed in the “wash-up” period before Parliament was prorogued on... Tech firms told to ‘tame toxic algorithms’ as Ofcom publishes child safety consultation On 8 May, Ofcom published its child safety consultation as part of its ongoing implementation of the Online Safety Act (‘OSA’). Announcing the consultation, Ofcom’s chief executive claimed the proposed measures ‘will deliver a step-change in online safety... Tax Disputes Podcast: France I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to Paris for a stimulating conversation between myself, my colleague, tax partner Charles Osborne and Julien Gayral, tax pa...