HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos  filed his tax returns on the basis that he was resident, but not domiciled in the UK. On that basis, he was entitled to the remittance basis of taxation….

The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good faith. The Agreement does not seek to replicate many of the rights which UK citizens and businesses had under EU law. There is no general non-discrimination provision. Double…

Marcos Álvarez Suso (Auditing Department of the Spanish Tax Authorities) The digital economy in the 21st century New business models associated to the so-called digital economy are blossoming in all type of economic activities all over the globe. Among many other examples of increasingly digitalized business we can find online goods sellers, streaming television services, remote…