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Taxing Matters: Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

Published on 16 Jul 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

Tribunal confirms loans from remuneration trust were disguised remuneration

Published on 11 Jul 2024. By Liam McKay, Senior Associate

In allowing HMRC's appeal in part, the Upper Tribunal determined that payments received under a remuneration trust scheme were caught by the anti-avoidance provisions in Part 7A of the Income Tax (Earnings and Pensions) Act 2003.

Dealing with HMRC information notices

Published on 04 Jul 2024. By Adam Craggs, Partner and Daniel Williams, Associate

Considering three common types of HMRC information notices and the extent to which they can be challenged.

Tax Bites – July 2024

Published on 02 Jul 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

V@ update – June 2024

Published on 26 Jun 2024. By Adam Craggs, Partner

Welcome to the June 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

Tribunal awards taxpayer his costs due to HMRC's unreasonable conduct

Published on 20 Jun 2024. By Jasprit Singh, Senior Associate

In Aftab Ahmed v HMRC [2024] UKFTT 00236 (TC), the First-tier Tribunal granted the taxpayer's application for costs as HMRC had acted unreasonably in defending the appeal.

Tribunal allows entrepreneurs' relief appeal

Published on 13 Jun 2024.

In Cooke v HMRC [2024] UKFTT 272 (TC), the FTT allowed the taxpayer's appeal against HMRC's refusal of entrepreneurs' relief

Exploring tax from an ESG perspective

Published on 07 Jun 2024.

In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

A whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC

Published on 21 Feb 2024.

In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

A day in the life of a tax adviser with Jeremy Johnson

Published on 28 Nov 2023.

In this episode of Taxing Matters, we are joined by Jeremy Johnson, managing director of inTAX Limited.

A tax on conscience? A moral dilemma for non-residents

Published on 19 Sep 2023. By Liam McKay, Senior Associate

In HMRC v A Taxpayer, the Upper Tribunal (UT) considered the meaning of ‘exceptional circumstances’ for the purposes of the statutory residency test (SRT) in FA 2013. In overturning the decision of the First-tier Tribunal, the UT held that moral obligations, specifically the need to care for close relatives, were not exceptional circumstances, creating a potential dilemma for individuals when it comes to managing their tax residency status and their family life.

Corporate tax update - Final quarter 2015

Published on 29 Jan 2016.

Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly. In this edition we highlight some of the key tax developments of interest to UK corporates from the final quarter of 2015.

ISDA Master Agreements

Published on 13 Jan 2025. By Jake Hardy, Partner and Simon Hart, Partner, Head of Commercial Disputes

Banking litigation partners Simon Hart and Jake Hardy discuss the world of ISDA Master Agreements, close out mechanics and a rather opaque investment bank wheeze involving counter hedging strategies, which counterparties miss at their financial peril.

Restructuring Plans – A Sea Change?

Published on 26 Oct 2022. By Paul Bagon, Partner and Will Beck, Of Counsel and Knowledge Lawyer

Full and frank disclosure means more than just putting relevant matters in evidence – a new year warning in UKIP v Braine & Others

Published on 24 Jan 2020. By Geraldine Elliott, Partner

New year, new reminder of the obligation to make full and frank disclosure in without notice applications, this time in the context of a falling out within the UKIP party. The obligation can only be satisfied by drawing the court's attention to legal or factual matters which could undermine the applicant's own application; it is not enough to simply put relevant matters in evidence before the court (UKIP v Braine & Others). Injunction, confidential, publication and non-disclosure.