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Zalando loses its challenge against DSA VLOP designation
On 3 September 2025, the General Court of the European Union delivered the first major judicial interpretation of the DSA in its dismissal of Zalando’s challenge against its designation as a “very large online platform” (“VLOP”) under the EU’s Digital Ser...
German Federal Fiscal Court rules against double RETT on share deals
In a decision dated 9 July 2025, the German Federal Fiscal Court (docket no. II B 13/25) addressed the issue of a double assessment of real estate transfer tax (RETT) in share deals, where the contractual obligation transaction (signing) and the actual tr...
How to respond to information requests from HMRC
A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes in the UK, we discussed what to look out for when HMRC open an enquiry – and noted that enquiries often go on for years...
What to do when HMRC open an enquiry
Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of HMRC enquiries – which will often last for years, given that there is no statutory time limit for HMRC to complete an...
How to handle tax disputes in the UK
Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the reiteration of government promises not to increase taxes on working people, it can be expected that HMRC will continue to seek t...
The fair necessities: DMCC Act and unfair commercial practices under the microscope
Earlier this year, the majority of the unfair commercial practices (“UCPs”) provisions in the Digital Markets, Competition and Consumers Act 2024 (the “DMCC Act”) came into force and the Competition and Markets Authority (CMA) published guidance explainin...
Data claims must be proved: lessons from the Court of Appeal on non-material damage
Ever since Lloyd v Google [2021] stemmed the flow of mass data protection litigation, potential claimants have sought new ways to bring claims against controllers that, by accident or design, have ‘mishandled’ individuals’ their data. The recent Court of ...
FCA shares cyber resilience insights from 2024 industry discussions
The FCA has published a summary of discussions held throughout 2024 with industry members of its Cyber Coordination Group (CCG) programme, offering valuable insights for regulated firms navigating the cyber threat landscape. The insights centre on three k...
PepsiCo case comes to an end: Australian High Court calls last drinks and closes the bar
In a much anticipated, eagerly awaited decision, the Australian High Court today, in a 4/3 majority judgment in Commissioner of Taxation v PepsiCo, Inc (PepsiCo), found in favour of the taxpayer in its long running embedded royalty dispute against the Com...
Applying tax treaties to pensions payments: the First-tier Tribunal’s decision in Masters
Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in Masters. The case concerned payments from a UK self-invested personal pension (SIPP) to an individual who had become tax re...