Earlier quoted context omitted.
There is nothing - and I do mean nothing - written into the GDPR that requires any warnings of any kind, or places any limits on fines, except for $10/$20 million or 4% of revenue, whichever is greater. Period. A multimillion-dollar fine without warning for a first, minor violation is perfectly lawful under GDPR. The idea that "yes it says that but we can trust EU regulators to not assess large fines against foreign…
I think you and everyone making similar points in this thread are getting tripped up by the difference between rules-based regulation and principles-based regulation. This is unsurprising, given that the US is so heavily rules-based, but the EU (certainly the UK) has a long history of principles-based regulation. In rules-based regulation, all the rules are spelled out in advance, and the regulator is basically an au…
Unfortunately, so might students of history. Ask anyone in the UK who was working in the freelance or contract world when IR35 was introduced.
In that case, too, the principle was reasonable enough: there was a loophole in tax law where you could decide you're a contractor instead of an employee and pay less money despite for all other practical purposes still being an employee, and this was being actively exploited by some people.
In that case, too, the reality was that most people working in the sector probably wouldn't be challenged by the authorities, not least because the enforcers had limited resources.
But in that case, too, a given individual's status was often unclear. While some of those who were deterred or subsequently received penalties really were engaging in obvious tax avoidance, other reports described crippling penalties for people whose arrangements appeared to have been quite reasonable but to have fallen foul of someone in government's dubious interpretation.
This led to substantial amounts of time and money being collectively spent by the freelance and contractor community incorporating new legalese into contracts and paying for advice and taking out insurance policies. An entire trade body was formed primarily to deal with this threat. Even today, those of us who take on any sort of individual contract or freelance work from time to time have to be careful not to say or do certain otherwise reasonable things, or to allow others to do so, for fear of tipping the balance or giving any appearance that might be subject to challenge.
And the irony is that while the law arguably had some effect initially in getting contractors to go back to being permies if they were just using it as a tax dodge, overall it appears that IR35 has raised very little extra tax revenue for the government. It turns out that the vast majority of contractors and freelancers were operating in that fashion legitimately and continue to do so, and most enforcement actions appear to fail to the extent that the government even tries any more. Nevertheless, the rules still hang like a sword of Damocles above the whole sector.