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Decisions to be made on UK CFC State aid challenge
Now that they have had a chance to digest the decision in the EU State aid investigation into certain aspects of the UK CFC rules, affected taxpayers are asking a number of questions. Will the UK appeal? It would seem surprising if it did not - and we wou...
Recovery of Greek VAT on bad debts
In February, the Greek Supreme Administrative Court delivered a landmark decision (Decision 355/20.02.2019) in a test case, concluding that the way the Greek VAT Code dealt with bad debts on insolvency was contrary to EU law. The Greek VAT Code allowed bu...
Apps, photos and...financial services? The future of fintech
I can't remember the last time that I visited a branch of my bank, or wrote a cheque. I do all of my banking through mobile apps and pay using my contactless card or mobile payment services. It is estimated that approximately three quarters of the UK p...
The hidden fight on my phone (continues): SCOTUS weighs in
In recent years, you may have noticed an intense fervor brewing over what antitrust law can (and more importantly, should, if anything) do to regulate big tech. Among the current cases attracting attention is the European Commission's investigation into t...
Raising the bar for obtaining Dutch tax rulings
It is likely that the number of international tax rulings granted in the Netherlands will reduce significantly as a result of a new international tax ruling policy ("New ITR Policy"), a draft of which was released on 23 April 2019. Also, existing rulings ...
Economic substance requirements in the Crown Dependencies
Companies resident for tax purposes in Guernsey, the Isle of Man or Jersey are subject to economic substance requirements if they have income from a relevant business sector in any accounting period commencing on or after 1 January 2019. Legislation was ...
Repatriation of Italian dividends made simple. Or not?
BEPS legacies and ECJ recent decisions on the abuse of EU tax directives have increased the complexities around repatriating profits from Italy by way of dividend. Some recent Italian Supreme Court’s decisions have added unnecessary confusion to this alre...
FinTech Alliance - Proof the UK is no longer a challenger
On Tuesday the chancellor, Philip Hammond, announced the launch of the fintech Alliance, an initiative to bring together various elements of the disparate UK fintech environment to cement its position as a "powerhouse". As one would expect, the announceme...
French Digital Services Tax: is this interim measure compliant with higher legal standards?
Introduced as a temporary measure designed to deal promptly with one of the main challenges faced by international tax law - coping with an ever changing modern economy - the French Digital Services Tax (the “French DST”) was recently adopted by the Frenc...
Does your office plant really improve your work?
Until relatively recently, very little thought was given to where and how we work. The psychological impacts of architecture and design, while they have been studied for decades, seem to have attracted very little media attention. Despite staff costs a...