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Right to appeal administrative sanctioning proceedings in Spain The right to appeal in criminal cases is embodied in Article 2 of Protocol No. 7 to the European Convention on Human Rights (ECHR) to which Spain is a party. This right is broader in scope than its counterpart in the International Covenant on Civil and Po... Recent changes to special CIT regimes applicable to Spanish real estate investments Various legal developments that recently entered into force in Spain impact two special tax regimes widely used by international real estate investors. Law 11/2021 of 9 July 2021 on measures to prevent and combat tax fraud amends the SOCIMI (Spanish REIT)... High energy prices, in-the-money hedges and another special purpose tax for the UK The UK government is proposing to introduce yet another new tax, the Public Interest Business Protection Tax (PIBPT) (even though the ink on the Health and Social Care Levy Act 2021 has hardly dried and the Finance Bill already makes provision for a new R... General Court annuls European Commission’s 2009 €1.06 billion fine on Intel Thirteen years after the European Commission imposed a EUR 1.06bn fine on US chipmaker Intel on charges of abusing its market dominance and seeking to exclude a competitor from the market, Intel has successfully persuaded the General Court to annul the fi... Engage early with HMRC to obtain exemption from the uncertain tax treatment rules Large businesses are encouraged to provide relevant information to HMRC at an earlier stage to gain exemption from notification under the uncertain tax treatment (UTT) rules. This is a key message in the revised draft guidance which is open for consultati... UK Ring-fencing Review - Update Last week the panel in charge of leading the review of the UK bank ring-fencing regime (the RFPT Panel) published an update on the progress of the review.  While the Panel's final report and recommendations will be published later in the year (the update ... UK Investment Firm Prudential Regime - "fit for purpose" The new Investment Firm Prudential Regime (IFPR) that applies to MiFID investment firms regulated by the UK Financial Conduct Authority (FCA) came into force on 1 January 2022. These include current firms within scope of the regulator's prudential sourceb... European Commission expresses competition concerns with consumer Internet of Things sector The European Commission has published its final report in its inquiry into the consumer Internet of Things (IoT) sector, confirming its preliminary concerns (as reported in our previous Lens post). In the words of Executive Vice-President Margrethe Vestag... Biting off more than they can chew? French regulator issues more cookie fines to Big Tech On the last day of 2021, the French regulator, the Commission Nationale de l'Informatique et des Libertés (CNIL), issued fines to Facebook Ireland Limited, Google LLC and Google Ireland Limited for failure to comply with the French Data Protection Act. Th... A question of substance – a first look at the EU Commission's "Unshell Proposal" Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax authorities as well as an increase in substance requirements – have found their way into a new legislative proposal by the Europ...