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Q: What's unallowable, but not disallowed? A: Interest on a Kwik-Fit loan. The question "what's unallowable, but not disallowed?" is the riddle thrown up by the latest First-tier Tribunal decision on the loan relationships unallowable purpose rule in Kwik-Fit. Kwik-Fit had an intermediate holding ... German Ministry of Finance publishes guidance on transitional provision of new RETT law The German Ministry of Finance has published guidance on the transitional provision with respect to the revised German Real Estate Transfer Tax (RETT) provisions which became effective as of 1 July 2021 (see this earlier post). It provides welcome clarifi... Is Spanish tax form 720 used to declare foreign assets of Spanish residents contrary to EU law? Back in 2012, the Spanish Government approved a tax amnesty by means of which Spanish tax residents could regularise their tax situation by giving details of any undeclared assets and income they held abroad and pay tax at a reduced rate of 10% without ta... Triple Damage – Supreme Court rules on the right to claim LDs in Triple point case In a scenario most tech lawyers will dread, the Supreme Court recently scrutinised the drafting and construction of a liquidated damages clause, and the meaning of ‘negligence’ in a liability cap, in the case of Triple Point Technology, Inc v PTT Public C... The Edge of Glory?: Will DABUS ‘success’ in South Africa and Australia be repeated in the UK? Lady Gaga sings ‘I’m on the edge of glory and I'm hanging on a moment of truth’.  Until now, the longstanding crusade to allow inventions generated by the AI machine DABUS to be patentable under existing national patent laws across different jurisdictions... India scraps retrospective application of tax on indirect transfers: what does it mean going forward? Last week the lower house of the Indian Parliament passed The Taxation Laws (Amendment) Bill, 2021 (the Bill). The Bill is significant. It removes the retrospective application of the rules on the taxation of gains arising on the transfer of shares in a f... Litigation on an epic scale... If you say it in a deep enough voice, "litigation on an epic scale" sounds like it may be the trailer for the latest summer blockbuster which is fitting because it is actually the Court of Appeal's (CoA) verdict on what was unleashed by the dispute betwee... Who is the weakest link? Cybersecurity in your supply chain With supply chain attacks on the rise, organisations should review the recommendations set out in a new ENISA report and monitor potential changes to the incident threshold levels for cloud providers and other digital service providers under the UK’s NIS ... Certain investment structures may need to be reviewed following the approval of the 2021 Spanish tax reform In our post published last November, we mentioned several tax measures included in two key draft bills which could affect foreign investors and individuals with economic ties to Spain. Both laws have been approved by Congress (i.e. the 2021 General State ... Can adopting a PET improve your privacy? As many organisations struggle to unlock the full value and innovative potential of their data, the Centre for Data Ethics and Innovation (CDEI) has been exploring the role privacy enhancing technologies (or PETs) can play in helping to enable data sharin...