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All clear on tax residence? The First-tier Tax Tribunal's unhelpful decision in the Development Securities case has been reversed by an Upper Tribunal decision which was published today and (at least for now) provides comfort that a lot more is required than a...
The EU Securitisation Regulation – where are we now? In this briefing we consider some of the open questions as to the scope of the new EU Securitisation Regime and how to comply with it Securitisations where new securities have been issued on or after 1 January 2019 are subject to the EU Securitisation...
Simple, Transparent and Standardised Securitisations: All Clear Now? In this briefing we consider how the STS regime, under the new EU Securitisation Regulation, is operating and how it may be impacted by Brexit. It has been six months since the new EU Securitisation Regulation, together with amendments to the Capital...
Decision time for the UK Government on the CFC State aid challenge The time limit for the UK to appeal the EU’s State aid decision in relation to the UK’s CFC regime is fast approaching, and we still do not know whether the UK itself will appeal. This is a political decision that needs to be made by the UK...
Employment Bulletin failure to enhance shared parental pay; employers required to record daily working time; transfer of undertaking under the Acquired Rights Directive; knowledge of disability Topics covered in this bulletin: No discrimination in failure to enhance shared...
The Corporate Tax Planning Law Review – inaugural edition Sara Luder and Dominic Robertson contribute the UK chapter to this Review which looks at the most important aspects of tax planning for multinational corporate groups in 20 different countries. This inaugural edition of The Corporate Tax Planning Law...
OECD's update on the digital economy Earlier today, the OECD's G20 Inclusive Framework on BEPS published a Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitisation of the Economy, detailing the technical work to be undertaken in respect of...
The SFC clarifies licensed corporations’ obligation to disclose internal investigations against outgoing employees The SFC clarifies licensed corporations’ obligation to disclose internal investigations against outgoing employees As part of the recently revamped licensing process, licensed corporations are now required to disclose information about any internal...
Pensions Bulletin 5th Money Laundering Directive; Ombudsman jurisdiction; Validating pre-1997 pension increases was “impermissible rewriting of history”; funding regime changes; DWP review of TPR New law 5th Money Laundering Directive Cases High Court rules on Ombudsman...
The Commission’s Day in Court: Hong Kong Competition Tribunal Hands Down First Two Judgments Under the Competition Ordinance This Client Briefing provides an overview of the Tribunal’s findings, and the key points of general significance to take away from these landmark cases. On 17 May 2019, the Hong Kong Competition Tribunal handed down two judgments in respect of the first...
Competition & Regulatory Newsletter European Commission fines AB InBev for abusing dominant position by restricting cross-border sales of beer The European Commission has fined AB InBev over €200 million for abusing its dominant position on the Belgian beer market. The Commission concluded...
The new prospectus regime - a guide for debt issuers In this briefing we seek to answer questions that may arise from the new prospectus regime, to ensure a smooth transition to the new regime. The date that the new prospectus regime takes full effect, 21 July 2019, is fast approaching. In this briefing we...
Is a digital services tax State aid? A feature of all the DSTs described in Deeksha Rathi’s earlier post is that they apply only to digital businesses that generate global and domestic revenues above certain (generally very high) thresholds.  These proposed taxes focus solely on...
Taxing the digital economy: my way or the highway will not lead to a longer-term solution There is a common recent development in the tax systems of the UK, France, Austria, Poland, Czech Republic, Italy, and Spain. All of these countries have announced some version of a digital services tax .
Tax and climate action: the UK's proposed plastic packaging tax Clearly, the pressure on governments to take climate action is increasing: each Friday, students all over the world strike to demand such action, Ireland and the UK have become the first two countries to declare a climate emergency and Australia’s...