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New double taxation agreement between the UK and Brazil In September 2022, Brazil and the UK announced a first round of negotiations for a double taxation agreement (DTA) following several years of discussions on technical and policy issues. It appears that the formal negotiations progressed well, given that a... CRR amendments under the 'Daisy Chain' Regulation - The treatment of third country subsidiaries' surpluses for resolution purposes Regulation (EU) 2022/2036 came into force on 14 November 2022 and makes targeted amendments to the Capital Requirements Regulation (575/2013/EU) (CRR) and consequential amendments to the Banking Recovery and Resolution Directive (2014/59/EU) (BRRD) to imp... EU expands scope of its cyber rules as NIS 2 agreed The EU has agreed changes to its cybersecurity rules. On 22 November 2022, the “NIS 2 Directive” received approval from the European Parliament. Yesterday, the text was also adopted by the Council of the EU, clearing the path for this to become law. What ... New taxes on non-Spanish-tax-resident individuals who indirectly hold Spanish real estate The Spanish Government recently published a proposal to tax non-Spanish-tax-resident individuals who hold Spanish real estate through one or multiple non-Spanish-resident entities under Spain’s Net Wealth Tax (NWT). The proposal also calls for a Solidarit... ICO warns immature biometric technologies could discriminate, and organisations may be investigated The ICO has warned organisations to carefully assess the risks if considering using emotion analysis technologies as they will be investigated if they fail to act responsibly, posing risks to vulnerable people, or if they fail to meet ICO expectations. Wh... The proof is in the (crypto) pudding: is Proof of Reserves a solution to crypto’s trust problem? In any normal week, reports that nearly half a billion dollars in cryptoassets had been stolen from a cryptocurrency exchange would be major news. Unfortunately for FTX, which has been having anything but a normal week, the reported hack is barely a footn... Interpreting tax treaties - Dutch Supreme Court clarifies relevance of later OECD commentaries In a previous post, Maarten van der Weijden indicated that a decision by the Amsterdam Court of Appeal on 22 December 2020 set the stage for a principled decision by the Dutch Supreme Court on how to deal with changes to provisions of the OECD model tax c... The promise and peril of scenario-driven climate risk management for banks and insurers Climate risk management is increasingly salient for boards of banks and insurers. In this publication, we outline key challenges for boards when discharging their responsibilities, given the uncertainty around the manifestation of climate risks. Although ... A capital mess? The Court of Appeal’s judgment in Centrica Overseas Holdings In what is thankfully an unusual occurrence in legal practice, I was about to press send on an email advising a client on an issue (in this case, the deductibility of expenses incurred in respect of the sale of a subsidiary), very much relying on the Uppe... Further changes to the UK's R&D tax regime Against a background of some “difficult decisions” being taken by Chancellor Jeremy Hunt in his 2022 Autumn Statement on 17 November 2022, the Treasury unveiled some further changes to the UK’s Research and Development (R&D) tax regime, signalling a move ...