In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like “fixed place of business”.

The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

In this episode of Taxed Out, <a href="https://www.ashurst.com/en/people/vanja-podinic/">Vanja Podinic</a> and <a href="https://www.ashurst.com/en/people/colin-little/">Colin Little</a> explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like &ldquo;fixed place of business&rdquo;.
The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

The commercial world is always changing and the legal landscape never stands still. Keeping pace with all those changes, and knowing how they affect your organisation, is a big responsibility and a challenging task. Ashurst Legal Outlook will keep you at the forefront of the most pressing legal issues, offering insights from legal experts across our international network.

The commercial world is always changing and the legal landscape never stands still. Keeping pace with all those changes, and knowing how they affect your organisation, is a big responsibility and a challenging task. Ashurst Legal Outlook will keep you at the forefront of the most pressing legal issues, offering insights from legal experts across our international network.

A podcast series that will keep you across the global trends and local issues that are shaping the legal landscape and impacting organisations.

Ashurst Legal Outlook Podcast

With regulation and legislation constantly shifting, Legal Outlook helps you stay one step ahead. In each episode, we flag legal changes to watch out for, explain what they mean for organizations, and suggest practical ways to respond. Featuring insights from seasoned legal professionals from across our global network.

With regulation and legislation constantly shifting, Legal Outlook helps you stay one step ahead. In each episode, we flag legal changes to watch out for, explain what they mean for organizations, and suggest practical ways to respond. Featuring insights from seasoned legal professionals from across our global network.

Ashurst Perkins Coie Legal Outlook

Data centres sit at the intersection of permanent establishment risk, transfer pricing, DEMPE, intangibles and withholding tax. 

Taxed Out: How and why data centres are becoming a global tax flashpoint 

1. The Evolution of Structured Leverage 

2. Choosing the Right Partner 

3. The Compatibility Test 

4. Playing the Long Game 

5. Beyond the Term Sheet 

6. New Entrants & Market Evolution 

7. Top Tips & What's Next 

Relationships are at the heart of successful structured leverage transactions. In this episode we discuss what makes the right financing partner, how borrowers should assess potential providers, and the key commercial and structural factors to consider.

As the European structured leverage market continues to mature, relationships are becoming just as important as legal documentation. But what separates a good financing partner from the right one?

Ashurst Perkins Coie partner Ruth Harris and AJ Storton, Partner at Art Capital, are joined by special guests Farrah Brown, Head of Debt Capital Markets, Europe, and Shawn Kaufman, Head of Debt Capital Markets, Americas, at Nuveen Real Estate. Drawing on their experience of both the European and U.S. markets, they discuss what borrowers should prioritize when selecting a structured leverage provider and how the market is evolving.

The conversation explores the importance of strategic relationships, operational alignment and track record, alongside key structuring considerations including warehouse facilities, advance rates, consent rights, mark-to-market provisions and recourse. The panel also compares the more established U.S. market with Europe's rapidly developing landscape and considers what increasing competition among providers means for borrowers.

As referenced by Ruth watch some useful 101 videos on the CREFC website.

To listen, search for "Ashurst Perkins Coie Legal Outlook" on Apple Podcasts, Spotify or your preferred podcast platform. You can also explore the full range of Ashurst podcasts at ashurstperkinscoie.com/en/podcasts/

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

 

Relationships are at the heart of successful structured leverage transactions. In this episode we discuss what makes the right financing partner, how borrowers should assess potential providers, and the key commercial and structural factors to consider.
As the European structured leverage market continues to mature, relationships are becoming just as important as legal documentation. But what separates a good financing partner from the right one?
Ashurst Perkins Coie partner <a href="https://www.linkedin.com/in/ruth-e-harris/">Ruth Harris</a> and <a href="https://www.linkedin.com/in/ajstorton/">AJ Storton</a>, Partner at Art Capital, are joined by special guests <a href="https://www.linkedin.com/in/farrah-brown-96ab516b/">Farrah Brown</a>, Head of Debt Capital Markets, Europe, and <a href="https://www.linkedin.com/in/shawn-kaufman-31291b5/">Shawn Kaufman,</a> Head of Debt Capital Markets, Americas, at Nuveen Real Estate. Drawing on their experience of both the European and U.S. markets, they discuss what borrowers should prioritize when selecting a structured leverage provider and how the market is evolving.
The conversation explores the importance of strategic relationships, operational alignment and track record, alongside key structuring considerations including warehouse facilities, advance rates, consent rights, mark-to-market provisions and recourse. The panel also compares the more established U.S. market with Europe's rapidly developing landscape and considers what increasing competition among providers means for borrowers.
As referenced by Ruth watch some useful 101 videos on the <a href="https://www.crefc.org/cre/cre/content/learn/educational-offerings.aspx">CREFC website</a>.
To listen, search for "Ashurst Perkins Coie Legal Outlook" on Apple Podcasts, Spotify or your preferred podcast platform. You can also explore the full range of Ashurst podcasts at ashurstperkinscoie.com/en/podcasts/
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.
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Relationships are at the heart of successful structured leverage transactions. In this episode we discuss what makes the right financing partner, how borrowers should assess potential providers, and the key commercial and structural factors to consider.

 Inside Structured Leverage: Episode 2 – The First Date. Choosing the Right Structured Leverage Partner

The Employment Rights Act 2025 is the most transformative shift in UK employment law in a generation. For boards of organisations with UK employees, there’s a lot to get to grips with.

In this episode, host Will Chalk is joined by Ashurst colleagues Crowley Woodford and Ruth Buchanan to unpack what the Employment Rights Act means in practice.

Crowley certainly doesn’t sugarcoat the scale of the impact: “It's no exaggeration that the Employment Rights Act is probably the most fundamental change in employment rights since the Thatcher era”. With that in mind, this episode covers a lot of ground in a short space of time.

Crowley pinpoints the changes to unfair dismissal as hugely significant, and outlines two changes of particular note for boards. In particular, he says that boards should consider preparing themselves for greater litigation risks when terminating highly paid employees. And he suggests some steps to mitigate these risks.

The Act also presents new corporate obligations in relation to sexual harassment. Ruth highlights governance issues for boards, as the compliance bar rises for organisations: “Employers are going to have to take the steps that are going to be specified in the regulations, but also take all other preventative steps that are reasonable in the circumstances.” Ruth suggests steps such as conducting risk assessments, publishing relevant policies and plans, establishing reporting mechanisms, and ensuring robust, proper complaints-handling procedures, etc.

And the big changes don’t stop there!

In short: this episode is an absolute must-listen for directors of organisations with UK employees. It will be 20 minutes very well spent.

To listen to this and subscribe to future episodes in our governance mini-series, search for “Ashurst Legal Outlook” on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at ashurst.com/podcasts.

To receive updates and alerts on the issues raised in this podcast mini-series, subscribe to Ashurst’s regular Governance and Compliance Updates.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions. Please note that this episode was recorded before the King's Speech was delivered on 13 May 2026 which, contrary to all predictions, did not contain legislation to take forward disability end ethnicity pay gap reporting legislation.

 

 

 

The Employment Rights Act 2025 is the most transformative shift in UK employment law in a generation. For boards of organisations with UK employees, there&rsquo;s a lot to get to grips with.
In this episode, host <a href="https://www.ashurst.com/en/people/will-chalk/">Will Chalk</a> is joined by Ashurst colleagues <a href="https://www.ashurst.com/en/people/crowley-woodford/">Crowley Woodford</a> and <a href="https://www.ashurst.com/en/people/ruth-buchanan/">Ruth Buchanan </a>to unpack what the Employment Rights Act means in practice.
Crowley certainly doesn&rsquo;t sugarcoat the scale of the impact: &ldquo;It's no exaggeration that the Employment Rights Act is probably the most fundamental change in employment rights since the Thatcher era&rdquo;. With that in mind, this episode covers a lot of ground in a short space of time.
Crowley pinpoints the changes to unfair dismissal as hugely significant, and outlines two changes of particular note for boards. In particular, he says that boards should consider preparing themselves for greater litigation risks when terminating highly paid employees. And he suggests some steps to mitigate these risks.
The Act also presents new corporate obligations in relation to sexual harassment. Ruth highlights governance issues for boards, as the compliance bar rises for organisations: &ldquo;Employers are going to have to take the steps that are going to be specified in the regulations, but also take all other preventative steps that are reasonable in the circumstances.&rdquo; Ruth suggests steps such as conducting risk assessments, publishing relevant policies and plans, establishing reporting mechanisms, and ensuring robust, proper complaints-handling procedures, etc.
And the big changes don&rsquo;t stop there!
In short: this episode is an absolute must-listen for directors of organisations with UK employees. It will be 20 minutes very well spent.
To listen to this and subscribe to future episodes in our governance mini-series, search for &ldquo;Ashurst Legal Outlook&rdquo; on Apple Podcasts, Spotify or your favourite podcast player. You can also find out more about the full range of Ashurst podcasts at <a href="https://www.ashurst.com/podcasts">ashurst.com/podcasts</a>.
To receive updates and alerts on the issues raised in this podcast mini-series, subscribe to Ashurst&rsquo;s regular <a href="https://www.ashurst.com/en/insights/ashurst-governance-compliance-update-issue-79/">Governance and Compliance Updates</a>.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions. Please note that this episode was recorded before the King's Speech was delivered on 13 May 2026 which, contrary to all predictions, did not contain legislation to take forward disability end ethnicity pay gap reporting legislation.
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The Employment Rights Act 2025 is the most transformative shift in UK employment law in a generation. For boards of organisations with UK employees, there’s a lot to get to grips with. 

Governance & Compliance 13: Employment Rights Act reshapes risk and governance

In this episode, Tony Damian and Amelia Morgan are joined by special guest Emma Rapaport, Co-Editor of the Australian Financial Review's famed (and feared) Street Talk column.

Emma reflects on Street Talk's reputation and influence in the Australian market, the unique role it plays, and the responsibility that comes with it.

She unpacks a day in the life of a Street Talk journalist - including how sources and stories are managed on a daily basis.

Finally, Emma offers some observations on where the market is at, some brights spots to keep an eye on and the importance of sentiment in driving market activity more generally.

Watch all of our episodes in the Ahead of the Deal series here. For more information about our global corporate practice, visit our Corporate and M&A page.

The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

In this episode,&nbsp;<a href="https://www.ashurst.com/en/people/tony-damian/">Tony Damian</a>&nbsp;and&nbsp;<a href="https://www.ashurst.com/en/people/amelia-morgan/">Amelia Morgan</a>&nbsp;are joined by special guest Emma Rapaport, Co-Editor of the Australian Financial Review's famed (and feared) Street Talk column. Emma reflects on Street Talk's reputation and influence in the Australian market, the unique role it plays, and the responsibility that comes with it. She unpacks a day in the life of a Street Talk journalist - including how sources and stories are managed on a daily basis. Finally, Emma offers some observations on where the market is at, some brights spots to keep an eye on and the importance of sentiment in driving market activity more generally.
Watch all of our episodes in the Ahead of the Deal series <a href="https://www.ashurst.com/en/insights/ahead-of-the-deal-australian-m-and-a-briefing/vodcast/">here</a>. For more information about our global corporate practice, visit our <a href="https://www.ashurst.com/en/what-we-do/services/ashurst-legal/corporate-and-ma/">Corporate and M&amp;A page</a>.
The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.

Emma Rapaport, journalist behind the Australian Financial Review's influential Street Talk deals column, joins Ahead of the Deal. She reveals how the column operates to the quirky ways tips arrive, plus her outlook on the 2026 deal market.

Taxed Out: How and why data centres are becoming a global tax flashpoint

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