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How Brexit might limit challenges to HMRC decisions Looking at the CJEU decision in Luxembourg v B in the context of the UK's proposed new Financial Institution Notice (which would allow HMRC to request information from financial institutions without prior tribunal approval – and without the right to appea... Main highlights of 2021 Spanish tax reforms Shortly after the approval of the new Financial Transaction Tax and Digital Services Tax, the Spanish Government has submitted to Parliament two draft bills that contain significant measures affecting several taxes and resulting, generally, in increased t... The UK retakes control of financial services equivalence A number of equivalence decisions in respect of EEA member states have been laid in Parliament this week. The full list and further details are available here. By way of reminder: equivalence is, in short: an autonomous mechanism by which one jurisdiction... New Regulations for AI: the EU Parliament's proposals The legal and regulatory landscape surrounding artificial intelligence (AI) has been a point of significant discussion at EU level. Last month the European Parliament added to the debate, publishing the following three legislative proposals: a general leg... Soar in US AI patenting activity sees applications more than double from 2002-2018 Artificial intelligence (“AI”) and intellectual property (“IP”), have been under the proverbial microscope in recent times. One debate has focused on how AI should be accommodated in IP law in the UK (see The Lens post here), the EU (here) and on the inte... Spanish scrip dividends: Let the shareholder decide! In the last years, scrip dividends had become a very popular equity remuneration scheme for Spanish listed companies, as it helped them reduce the cash payout while allowing shareholders to choose and pick the form of remuneration and, consequently, its t... IP taxation: German nexus in unexpected circumstances The German Ministry of Finance (BMF) published the first guidance on one of the most hotly discussed German tax issues of the year on Friday, 6 November 2020. Background: Entry in German register as nexus to Germany In spring 2020, many foreign companies ... An (out)source of systemic risk? This morning the Financial Stability Board (FSB) published a discussion paper, which seeks to facilitate a broad discussion on current regulatory and supervisory approaches to the management of outsourcing and third-party risks. The paper doesn't propose ... The Spanish Supreme Court stands as the latest pacta sunt servanda watch The Court declined to disapply the reduced royalties withholding tax rate under the Spain-Switzerland Tax Treaty on the basis that the recipient of the royalties was not their beneficial owner because the relevant article did not include a beneficial owne... Argentina: new reporting regime for domestic and international tax planning arrangements The Argentine Tax Authority (AFIP) published a broadly drafted mandatory reporting regime for domestic and international tax planning arrangements in the Official Gazette on 20 October 2020. The Resolution became effective on the same day, but may require...