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The AI and IP conundrum: UKIPO joins the debate On 7 September, the UKIPO put out a call for views in order to better understand the implications of AI on IP policy, all in the interests of furthering its mission for the “UK to remain at the forefront of the AI and data revolution ”. Engaging in the...
Colombian beneficial ownership concept: Unsolved questions The 2019 Colombian tax reform introduced a new definition of beneficial owner for tax purposes. But the result may be an increase in uncertainty. The definition is overbroad, meaning that a significant volume of additional information may need to be...
Highlights from the 2021 Dutch Budget The Dutch government published its 2021 budget on 15 September 2020. The tax measures were largely as anticipated and, where corporate taxes are concerned, will generally result in an increase of the tax burden on multinational businesses.  The 2021...
Spanish courts adhere to Danish conduit cases When we were still immersed in uncertainty following the judgments of the CJEU on the Danish conduit cases, the Spanish High Tax Court (Tribunal Económico-Administrativo Central), a non-judicial and appeal body that forms part of the Spanish Tax Authority...
Buyer beware! Indemnity payments under a share purchase agreement are taxable in the hands of the purchaser, irrespective of their accounting treatment. This is what the Italian Supreme Court held in its decision no. 17011 of 13 August 2020, highlighting the importance...
Transatlantic rift — are we experiencing new EU/US divergence on big tech antitrust enforcement? The question of how antitrust enforcement should tackle the issue of big tech is nothing new.  Previously, there was a visible divide in antitrust enforcement between the EU, openly tackling tech giants, and the USA, where the antitrust enforcement...
Time to focus on digital clean tech? New report calls for UK government to support the sector The tech sector can help the UK to reach its target of net zero carbon emissions by 2050, according to a new report from Deloitte and TechUK. To do so, however, the UK government must support the emerging digital clean tech (or ‘climatetech’) sector. What...
Shape of future subsidy regime for the UK remains unclear No new rules before the end of the Brexit transition period The UK Government has confirmed that there will be no new UK rules on subsidies in place before the end of the Brexit transition period and that it will introduce legislation that will repeal...
New Dutch position on Brazilian interest on net equity is contestable On 28 August 2020, the Dutch State Secretary of Finance issued a policy decision (the "Decision") on the treatment of the juros sobre o capital próprio (also called interest on net equity, or "IoNE"). According to the Decision, IoNE should qualify as...
In search of certainty – EU to update competition rules on supply agreements On 8 September, the European Commission published its final working document evaluating the EU competition rules on supply agreements, namely the Vertical Block Exemption Regulation (VBER) and accompanying Vertical Guidelines. Echoing its earlier report...