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Italian Supreme Court sets aside discriminatory tax framework for non-EU pension funds based on free movement of capital A recent Italian Supreme Court decision could have far-reaching consequences for Italian tax provisions on cross-border dividend payments, in particular to non-EU investment funds. The decision No. 25963 of 2 September 2022 concerned the tax treatment of ... Overview of 2023 Irish Budget – key tax measures The Irish Minister for Finance, Paschal Donohoe, and the Irish Minister for Public Expenditure and Reform, Michael McGrath made their respective speeches to the Irish Parliament on Tuesday 27 September 2022. The Budget has been shaped in the context of si... Some imp-s'more-tant news... VAT has often held the answer to many of life's greatest mysteries. Why does my sandwich cost more if I eat in rather than eat out? Or if I say yes to wanting it heated, even if I do take-it-away? Answer: VAT. A cold sandwich to take away is a standard ra... Acquiring start-ups under the improved R&D regime The UK is, and intends to remain, a leading start-up hub for the tech and other sectors. R&D tax reliefs play a key role in incentivising investment in start-ups as they reduce the costs of innovation. The proposed changes to the R&D tax relief regime (am... One tech tip a day keeps the hacker away: NCSC publishes new guidance on how to keep IP safe in cyberspace Cyber risks, and the reputational fallout that might ensue, are not a new addition to the woes that keep IP practitioners up at night. Thankfully there are a growing number of resources to help you tackle this evolving threat. For example, back in May thi... SEPs and FRAND – English Courts Remain Essential SEPs and FRAND have been hot topics for a while and there are no signs of that changing any time soon. In the last couple of months alone there have been three English court decisions relating to SEPs and FRAND terms and the UKIPO has published a summary ... Merging crypto and ESG On 15 September 2022 the long-awaited transition to a 'proof-of-stake' consensus mechanism on Ethereum—referred to as 'The Merge'—finally took place. This move had environmental objectives at its core, marking a departure from the energy-intensive 'proof-... How to draft intragroup loans post-Blackrock to avoid transfer pricing problems Following the Upper Tribunal's decision in BlackRock that third party covenants (i.e. not from the borrower itself) could not be taken into account in determining the hypothetical arm's length loan, a commonly asked question is whether it is now necessary... Exclusive jurisdiction clauses and software licences – High Court reminds us that they’re not so simple When you are ‘buying’ (in this case, licensing) software, you want to know the risks associated with the deal. One key risk is where you could be sued under the licence. However, the recent High Court decision in IBM v LZLABS has highlighted some of the l... Acquiring start-ups under the improved R&D regime On 20 July 2022, the UK Government released draft legislation intended to implement a number of changes to the research and development (R&D) tax relief regime in the UK. The reliefs available are different for SMEs and larger companies, and the changes l...