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UK implements DAC 6 with guidance to follow
Final regulations implementing the EU directive commonly known as DAC 6 have now been made and come into force on 1 July, looking back as required to reportable arrangements entered into from 25 June 2018. HMRC has published a response document detailing ...
Digital newspapers and VAT
A Council Directive of November 2018 purported to finally allow Member States to apply a reduced or zero VAT rate to digital books and newspapers. The recent Upper Tribunal decision in Newscorp, however, suggests that, in the UK, digital newspapers were z...
Digital newspapers and VAT
A Council Directive of November 2018 purported to finally allow Member States to apply a reduced or zero VAT rate to digital books and newspapers. The recent Upper Tribunal decision in Newscorp, however, suggests that, in the UK, digital newspapers were z...
German Draft ATAD II Implementation Act
On December 10, 2019, the German Ministry of Finance published draft law which is intended to implement Article 9 and 9b of the Anti Tax Avoidance Directive ("ATAD II"). This Draft ATAD Implementation Act ("Draft AIA") therefore includes, inter alia, anti...
Dividend withholding tax: from abolition to reinforcement
Political developments are hard to predict. The case of the Dutch dividend withholding tax is a prime example of how quickly the political wind can change. What has happened? The Dutch coalition government headed by prime minister Mark Rutte launched pl...
HMRC Statement on State Aid Recovery
Happy Friday the 13th! Taxpayers who claimed the benefit of the UK’s CFC finance company exemption before 1 January 2019 will have shaken off their post-election hangovers this morning to find a 39 page statement from HMRC in their inboxes snappily entitl...
How do you explain AI?
This week the ICO, together with the Alan Turing Institute (The Turing), published draft guidance aimed at helping organisations explain decisions made with AI to affected individuals. Its research has shown that people are worried about machines making d...
The US's reaction to France's DST
In her recent post, Zoe Andrews suggested that, given the importance for the UK of securing a post-Brexit trade agreement with the US, now might not be the best time for the UK to introduce a digital services tax. Support for her view is to be found in ...
Fixed establishment through parent-subsidiary relationship
In Case C-547/18, Dong Yang Electronics, the ECJ has been asked to revisit the definition of fixed establishment (FE) for VAT purposes and to clarify whether a subsidiary can be considered an FE of its parent. How the ECJ has ruled to date A separate ent...
What does independent taxation mean?
The Labour Party has been in trouble this week due to its promise to scrap the UK tax marriage allowance. This allowance was introduced in 2015 and enables a non-working spouse or civil partner to transfer £1,250 of their tax personal allowance to their h...