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Back to the future... When I first qualified into tax, UK-UK transfer pricing was not a thing.  A UK company could lend money to a fellow UK group company without being required to impute interest on the loan.  A UK parent could guarantee the loan of its UK subsidiary without...
Should platforms like YouTube be liable for illegal uploads? As in all good legal conundrums, the answer is ‘well that depends’. If you are Advocate General Saugmandsgaard Øe in the recent joined cases Frank Peterson v Google LLC, YouTube LLC and others (C-682/18) and Elsevier Inc. v Cyando AG (C-683/18), then no....
How will the end of the Brexit implementation period impact eligibility for ECB collateral and the ECB purchase programmes? In response to the Covid-19 pandemic, central banks across the world set out a range of monetary stimulus packages. One such scheme is the European Central Bank’s Pandemic Emergency Purchase Programme (“PEPP”), aimed at supporting Eurozone monetary policy...
Consumer Internet of Things: European Commission launches sector inquiry Today, the European Commission launched a sector inquiry into the Internet of Things for consumer-related products and services in the European Union. Many of us are aware of the increasing number of ways in which the internet is embedded in the objects...
A simpler and more modern tax environment sounds good – but what about tax competition? The Apple case is seen as raising the (very) hot topic of how a multinational group like Apple should be taxed in a modern, digital world. In a briefing on our website, Mike Lane and Isabel Taylor review the case and consider the implications of the...
A simpler and more modern tax environment sounds good – but what about tax competition? The Apple case is seen as raising the (very) hot topic of how a multinational group like Apple should be taxed in a modern, digital world. In a briefing on our website, Mike Lane and Isabel Taylor review the case and consider the implications of the...
Court of Justice of the European Union approves continued use of EU model clauses, but strikes down EU-US Privacy Shield The Court of Justice of the European Union (CJEU) has published its long-awaited decision in the case of Data Protection Commissioner [Ireland] v Facebook Ireland Ltd. and Maximillian Schrems (referred to as “Schrems II”). The CJEU has confirmed that the...
3 July talks end in deadlock The Brexit talks re-started in London this week, with parties seemingly some way apart on a number of issues after last week's talks ended in deadlock. This briefing, prepared by Tolek Petch, lawyer in our trade unit, surveys the state of play as at 3...
Will there be a deal? The Brexit talks are ongoing – until a deal is in clear sight, businesses must remain mindful of the WTO alternative. This briefing, prepared by Tolek Petch, lawyer in our trade unit, contains a reminder of the key aspects of the WTO regime.
The EU's 'Capital Markets Union' reforms make cross-border securitisations easier. The UK should make similar reforms. The EU continues to press ahead with its Capital Markets Union ('CMU'). The High Level Forum ('HLF') recently published its final report containing 17 sets of recommendations intended to move the CMU towards completion. For each of the sets of...