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Finland amends its transfer pricing rules – long-awaited improvement or a new begin for transfer pricing disputes? Finland has amended its transfer pricing rules as of January 2022 enabling the Finnish Tax Administration (FTA) to make transfer pricing adjustments to the full extent permitted by the OECD Transfer Pricing Guidelines. Until now the FTA has had to accept,... UK regulatory reform in 2022 (part 2) As mentioned in our 'UK regulatory reform in 2022 (part 1)' blog, UK regulatory reform pushes on, with its key drivers of bolstering the UK’s position as a global financial centre and, as the UK Chancellor stated in a Speech in July 2021, a financial serv... UK regulatory reform in 2022 (part 1) UK regulatory reform pushes on, with its key drivers of bolstering the UK’s position as a global financial centre and, as the UK Chancellor stated in a Speech in July 2021, a financial services sector that is ‘open, competitive, technologically advanced a... Proposal to amend rules on VAT Directive rates On 7 December 2021, the EU Council agreed on a proposal to update rules on value added tax (VAT) rates. This proposal builds on the 2016 VAT Action Plan - Towards a single EU VAT area which aims to put in place a “definitive VAT system” based on the princ... The Spanish minimum 15% CIT rate: at the vanguard of the OECD/IF tax reform or in breach of a global agreement? For tax years starting as of 1 January 2022 or later, a minimum effective 15% Corporate Income Tax (CIT) will apply to large Spanish resident CIT payers, including tax consolidated groups, as well as Spanish permanent establishments. According to the Span... Concerns about cross-border mergers of Chilean companies Legal regulation of Chilean non-recognition regimes is scarce. Further details of their requirements are often derived from regulations and rulings of the Chilean Internal Revenue Service (IRS), on which taxpayers can rely. This is also true in the case o... The “Danish cases” controversy: the Spanish Tax Authority makes its move Following the path of tax audits stemming from the ECJ’s  rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax Authority has taken an official position on the subject by publishing a report that concludes that the special anti-abuse proc... Global minimum tax model rules The model rules for Global Anti-Base Erosion (GloBE) (a.k.a. Pillar Two of international tax reform) set a template for a jurisdictional-level corporate minimum tax system applying a minimum effective rate of tax (ETR) of 15%. This is expected to generate... Privacy implications of new COVID-19 pass checks: UK Government and ICO issue important guidance With the Omicron variant leading to rapid increases in COVID-19 infection rates, the Government has in the last few weeks published a sweep of new measures seeking to curb the trend. Perhaps one of the more controversial new rules relates to the mandatory... New UK Cyber Strategy promotes ‘whole-of-society’ approach We’d been promised the UK’s new National Cyber Strategy in Q4 2021 and yesterday (15th December), just before the Christmas break, it arrived. It replaces the current strategy, and follows publication of the Government’s Integrated Review earlier this yea...