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EU CFC State aid decision: the death of Cadbury Schweppes? The General Court released its decision in the UK's and ITV's appeals against the Commission's decision that the UK's CFC finance company exemption constituted State aid in so far as it applied to profits attributed to UK activities. Spoiler alert, the ap... Ok, I was wrong (or when tax doesn't follow form but in my view should have) A little over a year ago, I wrote a post called "The cautionary tale of Mr Bostan Khan". It was prompted by the Court of Appeal decision in Bostan Khan v HMRC and I wrote it because I thought it neatly illustrated the way that the tax consequences of tran... Net Zero: can tax help guide a unified approach? It is perhaps trite to say that tax can be used as the proverbial carrot and stick alike - or simply as a revenue raiser. It also goes without saying that policy design is a tricky affair, requiring both a precise determination of the desired behaviour, a... Taxing oil and gas: a new tax and an investment incentive The introduction of the “Energy Profits Levy” announced by the UK Chancellor on 26 May 2022 to take effect from the same date would appear to reverse the trend to reduce tax rates and increase incentives for investment as the North Sea oil and gas industr... “Reference” value: the new Spanish “market” value for real estate transactions Since 1 January 2022, taxpayers in Spain have had to pay tax on the “reference value” of their real estate acquisitions, which is a value approved by the Directorate General of the Cadastre (an administrative body within the Spanish Treasury Ministry). Th... Do you know how to manage your cyber supply chain risk? NCSC joins international partners to publish new supply chain guidance.   As organisations continue to shore up their own cyber defences, cyber criminals are increasingly looking for other routes into their systems. High profile supply chain attacks such ... Clearview lacking: ICO announces £7.5m fine for tech firm but questions remain The ICO made headlines this week when it announced its third largest GDPR-era fine to date, over £7.55m, against the controversial facial-recognition database provider Clearview AI Inc (Clearview). It has also issued an enforcement notice against the comp... Permanent establishment risk for virtual asset service and e-wallet providers in Italy One of the consequences of the entry-into-force of the Italian requirement for virtual asset service providers (VASPs) and e-wallet providers to register with the Italian authority overseeing financial agents and credit mediators (OAM, Organismo Agenti e ... Virtual asset service and e-wallet providers must register in Italy The Italian requirement for virtual asset service providers (VASPs) and e-wallet providers to register with the Italian authority overseeing financial agents and credit mediators (OAM, Organismo Agenti e Mediatori) for anti-money laundering purposes enter... DEBRA: A deleveraging allowance to reduce the debt-equity bias If one were to regard the European Commission’s Directive proposal to tackle the debt-equity bias in the tax system as the fruit of a discussion that started around a decade ago, it appears overly complex and unambitious at the same time. A Commission-pub...