Search results

Does some Member States' implementation of the legal professional privilege exemption from DAC6 reporting infringe higher-ranking Union standards? The way in which some Member States have implemented DAC6 raises legitimate concerns on its validity and compatibility with higher-ranking European Union standards. There is some reasonable doubt as to whether the legal professional privilege exemption fr... Income tax free securitisation of real estate in Italy In a recent ruling (No. 132 of 3 March 2021) the Revenue Agency has confirmed that SPVs used to secure proceeds from the direct ownership of real estate and most of their non-resident investors enjoy full direct tax exemption in Italy. “ReoCo” in the cont... DAC6 and legal professional privilege - request for a preliminary ruling On 21 December 2020, the Belgian Constitutional Court (Grondwettelijk Hof) requested a preliminary ruling from the CJEU on the DAC 6 rules, as transposed in Belgium (Case C-694/20), in the context of proceedings brought by the Flemish Bar Association (Ord... The corporation tax rise in pictures... For those who prefer to think in pictures, this chart from the OBR's 2018 report "Why have onshore CT receipts performed so well since 2013-2014?" is a very neat illustration of the balance of measures that have more or less offset each previous cut of th... Has the Chancellor really just announced a UK corporation tax rise of over 30%? TLDR – yes, it seems he has. The Chancellor is still trumpeting the rate as the lowest in the G7, even after the rise. But for those watching as the effective corporate tax rate shoots up above those of many of the UK’s competitors, the impact on the UK’s... UK’s March 2021 Budget: Spend now – pay later The UK’s headline corporation tax rate is set to rise to 25% from April 2023 (with a commensurate increase in the diverted profits tax rate) – but, in the short-term, economic support will continue, including through an enhanced loss carry-back, and a sup... The ePrivacy Regulation finally jumps out of the frying pan - but into the fire? The GDPR hasn't been the only EU privacy reform on the lips of politicians and businesses in recent years. The contentious ePrivacy Regulation, intended to replace the 2002 ePrivacy Directive and sit as "lex specialis" (i.e. governing the same area but ov... Germany and foreign-to-foreign IP transactions: the next act In 2020, many foreign companies were taken by surprise when they learnt that they might have fallen within the scope of German non-resident taxation with respect to past IP licence or sale transactions, even where only non-German parties were involved in ... Have you tried the ICO’s new AI toolkit? The Information Commissioner’s Office (ICO) is urging all organisations considering using data analytics on personal data to look at its new toolkit.  It aims to help organisations build data protection compliance into the start of any data analytics proj... Fintech: a core asset for Global Britain Ron Kalifa’s independent review of UK Fintech, announced in last March’s Budget, was published on 26 February 2021. The aim is to 'identify what more industry and government can do to support growth and competitiveness, to ensure that the UK maintains its...