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Concerns about cross-border mergers of Chilean companies Legal regulation of Chilean non-recognition regimes is scarce. Further details of their requirements are often derived from regulations and rulings of the Chilean Internal Revenue Service (IRS), on which taxpayers can rely. This is also true in the case...
The “Danish cases” controversy: the Spanish Tax Authority makes its move Following the path of tax audits stemming from the ECJ’s  rulings of February 2019 (the “Danish cases” rulings), the Spanish Tax Authority has taken an official position on the subject by publishing a report that concludes that the special anti-abuse...
Global minimum tax model rules The model rules for Global Anti-Base Erosion (GloBE) (a.k.a. Pillar Two of international tax reform) set a template for a jurisdictional-level corporate minimum tax system applying a minimum effective rate of tax (ETR) of 15%. This is expected to generate...
Privacy implications of new COVID-19 pass checks: UK Government and ICO issue important guidance With the Omicron variant leading to rapid increases in COVID-19 infection rates, the Government has in the last few weeks published a sweep of new measures seeking to curb the trend. Perhaps one of the more controversial new rules relates to the mandatory...
New UK Cyber Strategy promotes ‘whole-of-society’ approach We’d been promised the UK’s new National Cyber Strategy in Q4 2021 and yesterday (15th December), just before the Christmas break, it arrived. It replaces the current strategy, and follows publication of the Government’s Integrated Review earlier this...
Key data privacy developments in 2021 and what to expect in 2022 As another eventful year closes, data privacy developments have continued apace and there is more to expect to in 2022. In the UK for example, we await further clarity around the practical implementation of the rules on international transfers. We also...
Valueclick case: Paris Administrative Court of Appeal finds French permanent establishment In a decision dated 11 December 2020 (Valueclick case), previously covered in this blog, the French Administrative Supreme Court (Conseil d’Etat), set the framework, in the context of the digital economy, for the interpretation of the concept of permanent...
Cyber Essentials update for 2022 On 24 January 2022, the National Cyber Security Centre (NCSC) will introduce the biggest update to Cyber Essentials’ technical controls since its launch in 2014. Cyber Essentials is the simple, government-backed, cyber certification scheme that helps...
New AI assurance roadmap published – is this the route to safe AI? The UK government’s expert body for AI (the Centre for Data Ethics and Innovation or CDEI) has published “the world’s first roadmap to catalyse development of an AI assurance ecyosystem.” The roadmap was identified as a key action in the recent AI...
UK Law Commission confirms flexibility of the common law to accommodate smart legal contracts Last week, the UK Law Commission (the "Commission") published its much anticipated advice to the Government on the application of the legal framework in England and Wales to support the use of smart contract technology. While there continue to be some...