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Revised OECD tax treaty guidance as “temporary” COVID-19 travel restrictions continue to impact business operations The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on questions around the creation of permanent establishments and changes in tax residence as the guidance issued in April 2020....
President Biden’s tax proposals On January 20, 2021, Joseph R. Biden, Jr., took office as the US President.  As Washington’s focus now turns to policy-making, there are serious questions about the future US tax system and whether and to what extent the dramatic policy changes of former...
Is your joint copyright work purple or red/blue? ‘Two heads are better than one’ goes the old saying. Is this always right? It is true that collaboration can foster creativity and a better overall output. However, very often such collaborations later lead to painful copyright ownership disputes. This...
What the deal means for financial services: No change for now The Brexit trade deal lays down the details of the future relationship between the UK and the EU. The main document is the UK-EU Trade and Cooperation Agreement (TCA) which (at the time of writing) is in force provisionally, with ratification to follow ....
German taxation of non-resident license and sale of IP transactions: The struggle continues In 2020, many foreign companies were taken by surprise when they learnt that they might have fallen within the scope of German non-resident taxation with respect to past license and IP sale transactions, even where only non-German parties were involved in...
Ireland's Corporation Tax Roadmap: Overview of January 2021 Update The Irish Minister for Finance, Paschal Donohue, recently published an update to Ireland's Corporation Tax Roadmap (Roadmap). The Roadmap builds on the September 2018 publication and provides stakeholders with an overview of the actions Ireland has taken...
Precautionary measures: who gets to decide? In Heavyinstall, the CJEU decided that, where one EU Member State requests that another takes precautionary measures, such as seizing assets, to ensure that the first will be able to recover a tax debt, it is bound by the first’s “assessment of the...
When should you notify a data breach? New EDPB guidance provides practical examples New guidelines published on 14 January provide both practical examples of when to notify a data breach and “advisable measures” which organisations can take to mitigate their cyber risk.  Since the introduction of GDPR, the ICO has received over 30,000...
Legal reform of German withholding tax regime to come The German Government officially introduced a governmental draft for a reform of the German withholding tax (WHT) regime on 20 January 2021. The objective of the draft law is to simplify and digitalize the procedure to register the WHT, to issue tax...
Pillar Two: simplification is key Simplification was a key theme of the public consultation on the OECD’s two-pillared international tax reform proposal. Zoe Andrews has already commented on the consultation responses on Pillar One which seeks to re-allocate taxing rights to market...