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Dutch courts embrace Danish conduit cases Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to tackle abuse, particularly in the area of withholding tax exemptions on cross-border dividends and interest.  Courts in ... Rule of law vs Rule of judges – 1:0 In the tug of war between the Italian Parliament and Supreme Court in respect of the indirect tax treatment of indirect business transfers (see my earlier post), the Constitutional Court has come down on Parliament’s side: the form of the transaction must... The course of the UPC never did run smooth: the UK officially withdraws its participation In what has felt like death by a thousand cuts, the UK has officially withdrawn its ratification of the UPC Agreement.  For our earlier posts on the saga, see our blog posts here and here.     The written statement made by IP Minister Amanda Solloway to t... Loosening up access to information The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from financial institutions without prior tribunal approval. The stated aim of this measure is to “bring the UK’s rules into ... Sky v SkyKick battles on but permission to appeal granted: more uncertainty for brand owners These trade mark proceedings are quickly becoming a modern-day Jarndyce v Jarndyce.  As discussed in previous blog posts (here and here), Sky’s very broad trade mark specifications were cut down for being partly filed in bad faith. However, SkyKick’s ‘clo... Stay on the back pages - NCSC urges sport to take cyber security seriously The sports sector has been urged to tighten its cyber security after a range of attacks by hackers, including an attempt to sabotage a Premier League transfer deal. The UK’s National Cyber Security Centre (NCSC) has published its first ever report on thre... Cutting out the middle man: Digital Regulatory Reporting On 7 April 2020 the FCA published its 2020/21 Business Plan announcing that, in addition to its key priorities, one of its cross-sectoral priorities will be further work in the sphere of innovation and technology. In particular, the FCA intends to invest ... First Spanish rules on the taxation of carried interest For the first time, the Basque Country  and Navarre have enacted regulations on the Personal Income Tax treatment of carried interest. But it is currently unclear whether the new regimes, which reduce the tax burden on qualified carried interest income, c... Tax residence post-MLI Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD) residence tie-breakers have been removed from some of the UK's tax treaties in favour of competent authority determinations.... Fastest finger first? Nominet opens consultation on expiring .uk domains Highly desirable… Diamonds? Willy Wonka’s “Golden Ticket”? Contested by multiple parties… The Iron Throne? Gone in seconds… Glastonbury tickets? In fact, we are talking about attractive expiring .uk domain names, for example, generic or short domains that...