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Taxpayers face difficult choices in seeking resolution for international tax disputes Multinational companies increasingly face situations where two or more countries seek to tax the same profits. Recently enacted and upcoming legislative changes aim to address the perceived undertaxation of multinationals, and to redistribute taxing right... Peterson v Google LLC: a “so what?” for copyright? Should online platforms like YouTube and Uploaded be liable for copyright infringing content posted by their users? This was the critical question for the CJEU in Peterson v Google LLC and Elsevier Inc v Cyando AG and one which had vexed copyright lawyers... The Portuguese Recovery and Resilience Plan On 16 June 2021, the Portuguese Recovery and Resilience Plan (RRP) was endorsed by the European Commission (EC) and is the first recovery plan across the EU to receive such endorsement. The RRP is an instrument created within the EU’s Recovery and Resilie... Ban facial recognition in public: EDPB calls for new AI law to be tougher The EU’s groundbreaking AI proposals (see our Lens Blog), published 21 April 2021, have been broadly welcomed by the EU’s top data protection bodies (the EDPB and EDPS). However, they do have concerns, including around biometric surveillance, as set out i... International tax reform – now it’s time to get excited! In my previous blog, I couldn’t get too excited about the G7’s announcement on 5 June that agreement in principle had been reached on some key aspects of international tax reform because there was so little detail and an agreement between 7 seemed a drop ... International tax reform – now it’s time to get excited! In my previous blog, I couldn’t get too excited about the G7’s announcement on 5 June that agreement in principle had been reached on some key aspects of international tax reform because there was so little detail and an agreement between 7 seemed a drop ... The Subsidy Control Bill - What you need to know about the UK's proposed new subsidy control regime Following an 8 week consultation on its initial proposals earlier this year, the UK Government has published its response to that consultation together with the much-anticipated Subsidy Control Bill setting out the UK's new subsidy control regime.  As par... Plenty more phish in the sea? Cyber risks for SMEs in the supply chain 57% of small and medium-sized enterprises believe they would go out of business from a serious cyber attack, according to a new report by ENISA (the EU’s agency for cybersecurity). The report included a survey of SMEs in the EU, and highlighted that phish... Spanish National Court follows CJEU in placing burden of proving abuse on Spanish tax authorities In a ground-breaking ruling, the Spanish National Court (Audiencia Nacional) held that the burden of proof of abuse falls on the Spanish tax authorities and that the Spanish anti-abuse rule infringes European Union law. The ruling represents a turning poi... Exit tax: holding companies may not qualify for Italian participation exemption on migration The Italian Tax Authority confirmed that the participation exemption does not apply to shareholdings that are transferred abroad as part of a going concern (Principle of Law 10/2021). It follows that the participation exemption should be unavailable to mi...