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A question of substance – a first look at the EU Commission's "Unshell Proposal" Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax authorities as well as an increase in substance requirements – have found their way into a new legislative proposal by the...
Meta challenges CMA's first Big Tech prohibition On 23 December 2021 Meta Platforms, Inc (formerly Facebook, Inc) challenged the CMA's decision ordering it to sell off Giphy, the GIF-sharing search engine acquired by Facebook in May 2020. Meta is challenging the CMA's decision on six grounds, including...
Crypto: Promo Go Slow What feels several lifetimes ago in the world of crypto, in July 2020, HM Treasury published a consultation on bringing cryptoassets into the UK financial promotion regime. Yesterday, it published the response to that consultation. In a connected move,...
RAP (feat. statutory guidance): ICO releases draft enforcement strategy for consultation In December 2021, the ICO released its revised draft Regulatory Action Policy (RAP); revised draft Statutory Guidance on Regulatory Action; and draft Statutory Guidance on PECR Powers, proposed to replace the ICO’s existing RAP and statutory guidance. The...
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 supply, the...
NCSC helps boards tackle the Log4j vulnerability - the 'most severe computer vulnerability in years' The National Cyber Security Centre (NCSC) has reminded boards of their role in mitigating cyber risk in their organisations, publishing a blog just before Christmas on a critical new vulnerability impacting a wide range of companies. In their blog the...
New AI standards hub launched in UK This week the government launched a new AI standards initiative as part of its AI strategy (see my blog from last September for information on the strategy generally). New research predicts that AI use in business is expected to double in the next twenty...
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 operate?...
Finland amends its transfer pricing rules – long-awaited improvement or a new begin for transfer pricing disputes? Finland has amended its transfer pricing rules as of January 2022 enabling the Finnish Tax Administration (FTA) to make transfer pricing adjustments to the full extent permitted by the OECD Transfer Pricing Guidelines. Until now the FTA has had to accept,...
UK regulatory reform in 2022 (part 2) As mentioned in our 'UK regulatory reform in 2022 (part 1)' blog, UK regulatory reform pushes on, with its key drivers of bolstering the UK’s position as a global financial centre and, as the UK Chancellor stated in a Speech in July 2021, a financial...