Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
HMRC has announced a new policy on the recovery by employers of VAT charged on investment services provided to their DB pension schemes. Until 18 June 2025, the extent to which an employer could recover any VAT paid on...more
Starting from January 2025, staff secondments are subject to VAT even where limited to the mere reimbursement of costs, provided that the relevant payment received qualifies as consideration for a supply of services. This...more
Introduction - After a long gestation, the much heralded new UK fund structure, the Reserved Investor Fund (“RIF”) is finally expected to be available from 19 March 2025....more
Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more
Previously, for credit insurance covering the price of a supply including VAT, in so far as the credit insurer was subrogated in the rights of the insured supplier, the insurer was entitled to exercise the VAT refund right...more
On 16 January 2025, the President ratified Supplementary Law No. 214/2025, marking a significant step in Brazilian tax reform. This new law outlines the framework for the IBS, the CBS, and IS, while also establishing the IBS...more
The modification of the French administrative guidelines puts an end to an asymmetrical situation where the taxpayers had 2 years to claim incorrectly invoiced VAT and the French tax authorities had 3 years to reassess...more
The issue of the taxability of intra-group supplies in the context of a VAT group has been of concern to taxpayers for many years. The starting point was the question of whether a VAT group existed between a foundation under...more
Company belonging to Euro 750 Mio Group, will pay DST regardless of their digital service turnover in Italy. ...more
The Spanish Tax Court clarified that a sale and lease-back transaction carried out between an entity and a bank does not qualify as a supply of goods (here Real Estate) for VAT purposes, but as a financing transaction....more
Digital goods are currently taxed in 31 states. The large market states where such products and services are generally not subject to tax, include California, Florida, Illinois, Massachusetts, New York and Virginia....more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
After more than two decades of discussions, the National Congress approved, and the President of the Republic enacted the final text of the Constitutional Amendment n. 132/2023, known as the Brazilian Tax Reform on...more
The government has just issued an amendment n°5374 to the draft Finance Bill for 2024 aimed at clarifying the VAT regime applicable to the para-hotel and serviced residences sector, following the Administrative Supreme Court...more
Zgodnie z projektem Rozporządzenia Ministra Zdrowia opublikowanym 2 maja na stronach Rządowego Centrum Legislacji, 1 lipca 2023 r. stan zagrożenia epidemiologicznego ma zostać odwołany. Projekt skierowano do uzgodnień i...more
According to the draft Decree of the Minister of Health published on 2 May on the Government Legislation Centre’s website, the state of epidemic emergency is scheduled to be terminated on 1 July 2023. The draft has been sent...more
Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more
Tulum, Cabo, Cancun, and Playa del Carmen are not only wonderful vacation destinations in Mexico, they are also very attractive destinations for American investors. Clients interested in acquiring real estate in Mexico, often...more
Due to the anonymity of non-fungible tokens’ (“NFTs”) transactions, sellers face practical difficulties in determining whether or not they should charge Spanish Value Added Tax (“VAT”) to the buyers on sales through online...more
As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has launched a public consultation on the VAT treatment of fund management. The consultation, published on 9...more
Approximately 30% of the global market is related to intellectual property. While intangible goods cannot be touched or seen, they are all too real. For companies around the world, one of the most important intangible assets...more
The Spanish Tax Authorities (“STA”) have issued the first ruling analysing the Value Added Tax (“VAT”) treatment of the sale of non-fungible tokens (“NFTs”) that grant the buyer a right to use an underlying digital artwork....more
Welcome to February’s edition of our UK Tax Round Up. This month’s edition includes updated guidance on the VAT treatment of contractual termination payments, updated HMRC guidance on the assessment of “substantial”...more
HM Revenue and Customs (HMRC) now considers that charges made by businesses to their customers to withdraw early from agreements to supply goods or services are payments for a supply and potentially subject to value added-tax...more
In this roundup, we look at some of the key cases in corporate and real estate tax from December 2021 to January 2022, including the value–added tax (VAT) decisions on input VAT that was not passed on to final consumers and...more