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Non-resident French capital gains tax now compatible with EU principles (at least partially)
As part of the French Amended Finance Bill for 2021, the French Parliament amended the French capital gains tax applicable to non-French residents on transfers of significant shareholdings (Section 244 bis B of the FTC, applicable subject to double tax tr...
Notification of uncertain tax treatment by large business
Putting aside for now whether this new notification regime is necessary and apt to reduce what HMRC refer to as the tax gap attributable to legal interpretation and quantify at £4.9bn, it is encouraging to see that the model is much improved from the orig...
Thinking of moving to Spain? Expect a fantastic climate and a special income tax regime for expats which may be about to get even better
Right before the summer break, the Spanish Government has published a draft bill (Anteproyecto de Ley de fomento del ecosistema de las empresas emergentes) which significantly improves the existing special income tax regime for expats, with the hope of at...
Can data trusts help unlock the value of your data?
Managing responsible and efficient data sharing is vital for businesses in an increasingly digital age. It is also key to realising the UK Government’s ambitions set out in the recent National Data Strategy of unlocking the vast potential of public - and ...
Small issue, big consequences; increased regulatory focus on the GDPR representative requirement
Those of us working in data privacy compliance have had a busy few years; we have been particularly occupied with the many 'big ticket' items such as Brexit, new rules around international transfers, and of course the implications of data collection durin...
The consequences of paying with data
Never has the use of data had a bigger impact in our lives as consumers. However, there is a growing concern that individuals are losing control over their data as a result of the shift from traditional payment mechanisms to ‘paying with their data’- and ...
Statutory damages for IP infringement: ‘It’s a wonderful world’?
It is one thing to own an IP right in the UK. It is another thing entirely to actually enforce an IP right in the UK courts. First, you have to win the often long drawn out trial battle on liability. Second, if you are victorious on liability and if yo...
French tax treatment of the gains arising from “management packages”: a new era opened by the French Administrative Supreme Court?
On 13 July 2021, the French Administrative Supreme Court (Conseil d’Etat) handed down three important tax decisions which shed new light on the conditions under which the French tax authorities may tax as salaries gains arising from “management packages” ...
UK government consulting on new "world-leading" pro-competition regime for digital markets
The UK government is seeking views on its proposed pro-competition regime for digital markets. This is the latest step towards establishing a new regulatory regime for digital markets in the UK, and builds on the recommendations in the Furman Review and a...
German Federal Ministry issued long-awaited decrees on cum/cum-transactions and securities lending
As an aftermath to recent fiscal court decisions on cum/cum transactions, the German Federal Ministry of Finance ("BMF") has reconsidered its guidance on the transfer of beneficial ownership in securities lending transactions and in cum/cum-transactions. ...