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What can we learn from Starbucks and Fiat? The European Court ruled yesterday that the EU Commission had not been able to demonstrate that the advance pricing agreement between Starbucks and the Dutch tax authority amounted to illegal State aid. 
Competition & Regulatory Newsletter President-elect of the European Commission, Ursula von der Leyen, announces her new College of Commissioners On 10 September European Commission President-elect Ursula von der Leyen presented her list of nominees for the next College of Commissioners. In...
Where should the holding company be? In any cross-border merger transaction, an early question will often be where the holding company for the merged group should be located.  This is not just a tax question - the location of the business, stock market requirements and practical issues...
Tax and the City Review for September 2019 Mike Lane and Zoe Andrews consider the decision in Hargreaves Lansdown and the latest cases on tax indemnities. They also look at the UK’s consultation on the implementation of DAC6 and draft legislation following Gallaher. The UT overturns the...
UK CFC rules and EU State aid: an update A lot has happened since April when the European Commission published its full decision on the UK’s CFC rules explaining why it considers that the CFC rules for exempting non-trading finance profits constituted State aid to the extent that the...
Dawn raids and data dumps: handling the practical realities of tax disputes In the past, many tax disputes were run as technical debates, where the parties (largely) agreed the facts, the court had little contested evidence to consider, and the focus was on the precise interpretation of the law.  .
Transforming Interest Rate Benchmarks - Developments in euro land EONIA, the overnight rate for euro is being discontinued which means deals will need to be transitioned to an alternative rate.  EONIA, the overnight rate for euro is being discontinued: From 2 October 2019 when €STR, the new risk free rate for euro...
73rd International Fiscal Association (IFA) Congress in London I post this blog on my way to the Women of IFA Network (WIN) Meet & Greet Reception, the first of many WIN activities taking place between today and Thursday during the 73rd IFA Congress in London.
Employment Bulletin pro-rated holiday pay for part-year employee; Work Council’s opinion; ill health job losses; consultation on parental leave rights; Greek Data Protection Authority fines employer Topics covered in this bulletin: Employer should not have pro-rated holiday...
Competition & Regulatory Newsletter This edition looks at recent merger control, antitrust and State aid developments worldwide In this update, we look at the following developments: UK’s Competition and Markets Authority accepts final undertakings to address concerns in Rentokil/MPCL...