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There’s only one POEM – but it’s not of the rhyming sort! The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation. As taxing rights of a party often depend on the place of residence of the taxpayer, it is important that a treaty has ... Section 899 compromise shifts international tax landscape The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind Ravichandran, a tax partner at Cravath, Swaine & Moore LLP on 24 June 2025. It was a follow-up to our conversation with Arv... French Digital Services Tax under Constitutional Review: Key opportunities and deadlines for taxpayers On 17 June 2025, the French Administrative Supreme Court (Conseil d’État) referred a preliminary question on the constitutionality of the French Digital Services Tax (DST) to the French Constitutional Court (Conseil constitutionnel). This important develo... Advocate General recommends Court of Justice dismisses Google's Android appeal Advocate General (AG) Kokott has proposed that a EUR 4.124 billion fine imposed on Google be upheld and that Google's six grounds of appeal are dismissed in their entirety. The opinion is not binding on the Court of Justice (CJ) , and it remains to be see... To enforce or not? AI divides regulators Staying abreast of enforcement trends is a critical element of the General Data Protection Regulation (GDPR) risk landscape for organisations and something we regularly discuss with clients – particularly in relation to AI. So what trends are emerging in ... Vietnamese jets and double tax treaties What can an aircraft leasing case tell us about the interpretation of tax treaties? Quite a bit, as it turns out. In VietJet Aviation, the UK Court of Appeal dismissed the borrower’s arguments that an assignment of debt was invalid because the assignee wa... CMA launches consultation on releasing Google from Privacy Sandbox commitments On 13 June 2025, the UK Competition and Markets Authority (CMA) published a notice of intention to release Google from commitments initially put in place to ensure that its Privacy Sandbox was developed in a way that benefits consumers. The CMA opened its... Amazon commits to CMA to tackle fake reviews On 6 June 2025, the CMA announced that Amazon had agreed to undertakings in order to tackle fake and misleading reviews. The details of the undertakings are set out here. These undertakings were accepted in relation to the CMA's investigation initiated on... UK Supreme Court in Dolphin Drilling decides that the meaning of “incidental” depends on statutory context The Supreme Court in Dolphin Drilling dismissed the taxpayer’s appeal, agreeing with the Court of Appeal that the provision of accommodation for offshore workers was an independent end in itself and not (as the First-tier Tribunal and Upper Tribunal had h... Data laws rebooted: Data (Use and Access) Bill agreed, as amendments tabled to the EU GDPR On 11 June, the UK’s Data (Use and Access) Bill (DUA Bill) passed in the House of Lords and is shortly set to become law. This marks the culmination of a multi-year, multi-government effort to introduce the legislative underpinning for new UK ‘smart data’...