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The Spanish tax court places the blame on the Spanish tax authorities' abusive use of the anti-abuse rules In broad terms, general anti-abuse rules tend to lead to uncertainty insofar as they are built on vague legal concepts such as the “artificiality” of a given transaction. Spanish domestic rules include two main anti-abuse rules used to tackle abusive tax...
EU publishes draft adequacy decisions for transfers of personal data to the UK The EU Commission has published two draft adequacy decisions for transfers of personal data to the UK, one under the GDPR and the other for the Law Enforcement Directive. This will be welcome news to many UK and EU businesses grappling with the...
Peruvian Tax Court decision on beneficial ownership post-BEPS The Peruvian Tax Court (Tribunal Fiscal) denied the application of the favourable withholding tax rate provided for in Article 12 (Royalties) of the double tax treaty between Peru and Chile on the basis that the recipient was not the beneficial owner...
The ECB's Guide on the supervisory approach to consolidation in the banking sector Consolidation in the banking sector remains a hot topic, not only for market participants, but also for supervisors that are tasked with scrutinising proposed transactions. Until recently, European banks were lacking detailed guidance from regulators, in...
Brexit has happened, so what's next for securitisations? The UK left the EU single market at 11:00 pm (London time) on 31 December 2020. The Trade and Cooperation Agreement between the UK and the EU that has applied since then does not deal with the regulatory detail of cross-border financing transactions. In...
Data privacy and M&A: the issues you really can’t ignore We recently hosted a webinar as part of PL&B’s 33rd Annual International Conference on data privacy and M&A. During the session, we talked the audience through the key privacy compliance issues that we have come across. One of the first points we...
HMRC’s commitments to building and maintaining public trust in tax administration HMRC has powers to ensure everyone “pays their fair share of taxes” and in some cases, particularly where the powers tackle fraud, evasion and complex tax avoidance, these powers can be far-reaching.  It is important for maintaining and enhancing public...
Why are non-Spanish tax residents taxed in Spain on gifts and inheritances of non-Spanish securities and bank deposits? Nowadays, due to factors such as the greater mobility of people and capital, inheritances and gifts with an international component have become increasingly common. In this vein, heirs and donees have to be aware of the tax rules when assessing whether...
3 month reprieve for UK based .eu domain registrants - EURid As we warned in an earlier Lens post here, some UK entities who had registered some 142,000 UK based .eu domain names had a potentially big problem on their hands. The problem? From 1 January 2021 organisations who were established solely in the UK were...
3 month reprieve for UK based .eu domain registrants - EURid As we warned in an earlier Lens post here, some UK entities who had registered some 142,000 UK based .eu domain names had a potentially big problem on their hands. The problem? From 1 January 2021 organisations who were established solely in the UK were...