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How far does the fiction of a deeming provision extend? Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC. In its recent judgment, overturning the Court of Appeal’s decision, the Supreme Court held that a South African r... Subject access requests: new challenges arise from COVID-19 In the broader context of COVID-19, this briefing considers the ICO's draft guidance on the Right of Access, and offers some practical guidance for organisations in relation to DSARs. Although some organisations have seen a decrease in data subject a... Competition & Regulatory Newsletter On 6 May 2020 the UK Competition and Markets Authority announced its decision to block the completed acquisition of Footasylum plc by JD Sports Fashion plc following an in-depth Phase 2 investigation. The CMA noted the loss of competition between the par... Strings attached? Changes to the UK Government’s CCFF and CLBIL schemes to support large businesses This morning (19/5/2020) HM Treasury announced some important changes to the Covid Corporate Financing Facility (CCFF) and the Coronavirus Large Business Interruption Loan Scheme (CLBILS).  In this briefing we summarise the headline changes which in... New horizons: quantum computing and the banking sector In this article we provide a brief overview of the central tenets of quantum computing, before focussing on its potentially profound implications for the banking sector. The stage is set for quantum computing to bring about seismic changes in t... Getting the Deal Through - Debt Capital Markets (United Kingdom) 2020 UK and EU legal and regulatory framework of the debt capital markets, and factors which influence the market, including the documentation and execution of transactions. The UK has a very active debt capital markets known for their internationalism, ... No fixed establishment through parent-subsidiary relationship Or at least not automatically. A company established outside the EU does not have a fixed establishment for VAT purposes in an EU Member State merely because it has a subsidiary in that Member State. The Court of Justice confirmed this, and that a supplie... Partnership taxation: still a work in progress? Given the general view of partnership taxation – “they’re just transparent, right?” – it is somewhat surprising that how a partnership interest is accounted for, or whether a pre-sale profit distribution is made, or even poss... Latest decisions relating to breaches of directors’ duties This briefing looks at two recent cases where directors are disqualified, censured and criticised for breaching their duties. On 22 April 2020, the High Court ordered some former directors of Long Success International (Holdings) Limited be disqualified ... Working safely during COVID-19: new guidance for employers On Sunday evening, the Prime Minister called for employees who cannot work from home to be “actively encouraged” to return to the workplace. This marks a shift in messaging from "stay at home" to "stay alert", and provides ...