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Blog: Carpe Crypto Earlier this week, HMRC announced that it was the first UK law enforcement entity to seize an NFT. The turn of phrase struck me - how exactly does one go about seizing a cryptoasset?
The Transfer Pricing Law Review - 5th edition - United Kingdom chapter Preface by Steve Edge and Dominic Robertson for the fifth edition of The Transfer Pricing Law Review. UK chapter by Steve Edge, Dominic Robertson and Tom Gilliver.
Global Investigations Bulletin (February 2022) Our latest Global Investigations Bulletin for February 2022 is now available. This month, we discuss the evolving threat of regulatory investigations on environmental claims, and set out the latest news in global investigations and enforcement actions.
BLOG: Engage early with HMRC to obtain exemption from the uncertain tax treatment rules Large businesses are encouraged to provide relevant information to HMRC at an earlier stage to gain exemption from notification under the uncertain tax treatment (UTT) rules. This is a key message in the revised draft guidance which is open for...
Tax and the City Review for January 2022 Mike Lane and Zoe Andrews discuss improvements to the FX hedging tax rules; the Hargreaves case on withholding tax on interest; and the latest on international tax reform. This article was first published in the 14 January 2022 edition of Tax Journal.
BLOG: When is VAT due or paid? The CJEU’s judgment in Case C-156/20 Zipvit v HMRC clarifies that, for the purposes of Article 168(a) of the Principal VAT Directive, VAT is neither “due” nor “paid” (and, therefore, no input tax is recoverable) where the recipient of...
The Space Law Review – 3rd edition – Taxation chapter Taxation chapter by Tom Gilliver surveying the conceptual framework relevant to the direct taxation of space companies
BLOG: Full steam ahead for the UK’s implementation of the global minimum tax rules When is the best time to consult on the UK’s implementation of the OECD/IF GloBE model rules published on 20 December 2021 with the aim of requiring large multinational groups to pay a minimum 15% level of tax in each jurisdiction in which they...
The boundaries of indirect enforcement of foreign revenue law Autonomous non-commercial organization "Organizing Committee of XXII Olympic Winter Games and XI Paralympic Winter Games of 2014 in Sochi" v Pico Projects (International) Ltd [2021] HKCA 1798. We examine the application of the rule...
BLOG: 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...
International accords on tax, but what will happen next The BEPS project has made significant progress internationally and in domestic implementation in many countries – but in recent times its objectives have been forced to change and there is uncertainty as to whether or not the initial aspirations...
Global Investigations Bulletin (December 2021) Our latest Global Investigations Bulletin for December 2021 is now available. This month, we discuss the UK framework for debarment from public contracts, and set out the latest news in global investigations and enforcement actions.
The International Comparative Legal Guide - Corporate Tax 2022: Expert Analysis Chapter William Watson has contributed the Expert analysis chapter, "Fiscal State aid: Mixed Messages" to The International Comparative Legal Guide - Corporate Tax 2022. 
The International Comparative Legal Guide - Corporate Tax 2022: UK chapter William Watson and Zoe Andrews contribute the UK chapter to The International Comparative Legal Guide - Corporate Tax 2022
BLOG: Who needs BAFTAs when we have MAP awards? The OECD’s MAP awards for 2020 - not quite the BAFTAs, but (perhaps) still exciting for tax practitioners and authorities – were released alongside the 2020 MAP statistics on the OECD’s third Tax Certainty Day on 22 November 2021.