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Thoughts on the FCA's fund fee transparency proposals
Alternative investment funds may soon be required to report total cost of ownership in a standardised form. Work on new templates in ongoing, and fund managers need to be aware of the situation and to be involved in this important debate that has so far been largely overlooked.
Read moreInitial Coin Offerings – the digital financing process under global scrutiny
In an era of social media platforms and the like, the technological world creeps into its corporate counterpart of today. Initial Coin Offerings (ICOs) storm the corporate world by force, but what does the future hold for the new phenomenon?
Read moreFCA revisits FSCS funding proposals, and abandons plans for significant changes to professional indemnity insurance requirements
The FCA has published a second consultation paper on the thorny subject of FSCS funding. Although not widely reported so far, the new consultation makes it clear that the FCA will not, after all, consult on significant changes to personal investment firms' professional indemnity insurance requirements.
Read moreFCA allows confidential report to be scrutinised by Treasury Select Committee
The FCA has allowed the Treasury Select Committee to review its s.166 report into RBS' Global Restructuring Group (GRG) and has published an interim summary of the report. It is possible that the threat of publication will play on the minds of firms subject to s.166 reports, which may reduce cooperation with skilled persons and therefore the efficacy of this investigatory power.
Read moreThe FCA makes clear its expectations of financial advisers
FCA, regulatory, financial services
Read moreFCA criticised by Complaints Commissioner for its handling of enforcement limitation issues
The Office of the Complaints Commissioner recently upheld two complaints against the FCA for making a "serious mistake" in its management of limitation issues for two connected investigations. The Commissioner criticised the FCA not only for its mismanagement of the limitation issue, but also for the unnecessary delays in concluding its own internal investigation into these complaints.
Read moreDB Transfers - now what?
We know that the FCA is looking closely at defined benefit transfers; we already have the FCA's review of redress methodology and the defined benefit transfer rules. We now have the results of the FCA's review, into defined benefit transfers and it makes for uncomfortable reading for the financial services industry.
Read moreThe FCA: key themes for 2017/18
A look at key developments for the FCA in 2017 and looking forward to 2018
Read moreA level playing Field?
Frank Field's Work and Pensions Select Committee is intending to review the impartiality of defined benefit pension transfer advice. What could this mean for the advisory industry and its PI insurers?
Read moreLead market regulator's lawsuit includes professional advisers
In another significant development in the Securities and Futures Commission's (SFC) efforts to combat market misconduct-type activity involving listed shares in Hong Kong, the lead market regulator has commenced civil proceedings under Section 213 of the Securities and Futures Ordinance (Cap 571) in respect of China Forestry Holdings Co Ltd (in official liquidation). What makes the proceedings noteworthy is that besides naming the company and two of its directors as co-defendants, the regulator's civil complaint also names two co-sponsors and the auditor involved with the company's initial public offering (IPO) in 2009.(1)
Read moreECON scrutinises EBA's approach to RTS under PSD2
The EBA Chair has recently appeared before ECON to explain the EBA's approach to the development of RTS on strong customer authentication and secure communications under PSD2, and to answer concerns raised by the committee and others about these RTS.
Read moreFinancial Services: Minimising Risk in a Dawn of Opportunity
Over the last few years, firms have been asking themselves how they will make money in the post RDR world.
Read moreFCA approves 'independent' use of internal specialist advisers
Ever since RDR 'independence' rules were introduced nearly two years ago, financial advisers have sought clarification on referring clients to internal specialists within their firm for expert advice.
Read moreTax Bites - May 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal allows capital allowances claim for expenditure on construction of a quay wall at the Port of Liverpool
In The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC), the First-tier Tribunal allowed the company's claim for capital allowances in respect of expenditure incurred on the construction of a quay wall at a new deep-water container terminal at the Port of Liverpool.
Read moreTaxing Matters: Tax risk for professionals and professional businesses with Thomas Slipanczewski, Associate Director at Deloitte
In this episode of Taxing Matters, Senior Associate and Taxing Matters host, Alexis Armitage is joined by Thomas Slipanczewski, who is an Associate Director at Deloitte in their tax controversy team, to discuss task risk for regulated professionals and professional businesses.
Read moreHMRC Landfill Tax Crackdown
In recent years, HMRC has markedly increased its compliance activity in relation to Landfill Tax and it is therefore important that businesses operating in this area are aware of common issues that are triggering time-consuming tax enquiries, subsequent disputes and litigation.
Read moreCriminal Offences and Prosecutions for Tax Fraud
Adam Craggs and Daniel Williams consider HMRC's approach to investigation and prosecution of various tax fraud offences, and deferred prosecution agreements and unexplained wealth orders.
Read moreV@ update - April 2025
Welcome to the April 2025 edition of RPC's V@, our monthly update which provides news and analysis from the VAT world.
Read moreCourt of Appeal confirms that compensatory payments made to settle regulatory investigations are not penalties
In ScottishPower (SCPL) Ltd and others v HMRC [2025] EWCA Civ 3, the Court of Appeal held that compensatory payments made to consumers in settlement of regulatory investigations were not penalties and therefore were deductible for corporation tax purposes.
Read moreBusiness Briefing: Navigating The New US-UK Trade Tariffs
The Trump administration has introduced sweeping tariffs on goods imported into the United States. This move is expected to cause significant disruption to global trade, with notable consequences for UK businesses. As the ripple effects unfold, understanding the scope of the tariffs and how to respond strategically will be crucial for UK businesses looking to protect their margins, adapt their operations, and plan confidently for the future.
Read moreUT allows company's appeal as payment to EBT was not earnings of its employee
In M R Currell Ltd v HMRC [2024] UKUT 00404, the Upper Tribunal set aside the First-tier Tribunal's decision and held that a payment from a company to an employee benefit trust was not taxable earnings as the facts were distinguishable from those in RFC 2012 plc (formerly The Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45.
Read moreTax Bites: April 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreJudicial review in tax disputes – an overview
Judicial review remains an important tool for taxpayers to challenge HMRC's decisions, and it is important for taxpayers and practitioners to have a clear understanding of the judicial review process.
Read moreV@ update - March 2025
Welcome to the March 2025 edition of RPC's V@, our monthly update which provides news and analysis from the VAT world.
Read moreTaxing Matters: Navigating the human side of tax disputes with Mark Bevington of ADE Tax
In our latest episode of RPC's Taxing Matters, podcast host and Senior Associate, Alexis Armitage, is joined by Mark Bevington managing principal and founder of ADE Tax.
Read moreCourt allows taxpayer's appeal and agrees the "exceptional circumstances" exemption was satisfied
In A Taxpayer v HMRC [2025] EWCA Civ 106, the Court of Appeal allowed the taxpayer's appeal, agreeing with the First-tier Tribunal's decision that the "exceptional circumstances" exemption in paragraph 22(4), Schedule 45, Finance Act 2013, was satisfied.
Read moreHigh Court permits recission in EBT case enabling taxpayers to avoid IHT liability
In JTC Employer Solutions Trustee Ltd and others v Garnett and another, the High Court allowed the claimants' claim and permitted rescission in relation to various Employee Benefit Trust appointments to sub-trusts, with the result that there was no IHT liability as the mistake in creating the sub-trusts was sufficiently serious to render it unconscionable to leave the mistaken disposition uncorrected.
Read moreTaxing Matters: IWD 2025 special with Ele Theochari
This month, RPC Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Ele Theochari, Partner at Blick Rothenberg for a special episode to celebrate International Women's Day.
Read moreTribunal allows taxpayer's appeal in R&D relief claim
In Stage one Creative Services Ltd v HMRC [2024] UKFTT 1059 (TC), the First-tier Tribunal allowed the taxpayer's appeal against HMRC's decision to refuse R&D relief claims on the basis that the relevant projects were not "subsidised" or "contracted out".
Read moreTax Bites – March 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreSupreme Court rejects taxpayers' appeals and denies enterprise zone allowances
In R (ota of Cobalt Data Centre 2 LLP and another) v HMRC [2024] UKSC 40, the Supreme Court dismissed the taxpayers' appeals concerning capital allowances on enterprise zone expenditure, confirming the correct interpretation of section 298 of the Capital Allowances Act 2001.
Read moreTaxing Matters: Mike Ashley wins landmark data protection case against HMRC
At the end of January, Mike Ashley won his high-profile and landmark data protection case against HMRC, with the High Court concluding that HMRC wrongly withheld his personal information for over two years. In this month's episode of Taxing Matters, our host and Senior Associate, Alexis Armitage is joined by Megan Grew, Associate at RPC and part of Mike Ashley's legal team, to discuss the legal aspects of the case that led to a landmark data protection victory against HMRC for Mike Ashley in the High Court.
Read moreCustoms and excise quarterly update - February 2025
Welcome to the first edition of 2025! In this edition, we report on significant news items from critical changes to the Warehousekeepers and Owners of Warehoused Goods Regulations 1999 (WOWGR) to the newly implemented EU General Product Safety Regulation (GPSR). In our case law section, we analyse three recent decisions relating to the classification of wetsuits and aluminium roller banner stands and excise duty penalties.
Read moreV@ update - February 2025
Welcome to the February 2025 edition of RPC's V@, our monthly update which provides news and analysis from the VAT world.
Read moreThe Public Accounts Committee's report on tax evasion in the retail sector
Adam Craggs and Jasprit Singh share their thoughts on the Public Accounts Committee’s criticisms of HMRC’s approach to tax evasion in the retail sector
Read moreR&D claim upheld by Tax Tribunal
In Collins Construction Ltd v HMRC [2024] TC09332, the First-tier Tribunal (FTT) upheld the company's claim for R&D tax relief rejecting HMRC's claims that the expenditure was "subsidised" or tied to "contracted out" activities.
Read moreContentious Tax Review
A recap of important tax decisions from 2024, with a particular focus on interesting procedural and jurisdictional issues that the tax tribunals and courts considered, including decisions on anonymity in tax appeals, cross-examination in judicial review, and the consequences of failing to comply with tribunal directions.
Read moreTribunal allows taxpayers' appeals as they were carrying on a business with a view to profit
In GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeals and concluded that GCH Active LLP was carrying on a "business" with a view to profit at the time loan notes were transferred to it and the requirements of section 59A, Taxation of Chargeable Gains Act 1992 (TCGA), were therefore satisfied and the transfers were capital contributions rather than disposals and no chargeable gain arose.
Read moreTax Bites – February 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTaxing Matters: Nature's wealth: unlocking the power of natural capital with Daisy Darrell
In the latest episode of Taxing Matters, our host, Alexis Armitage is joined by Daisy Darrell, a Senior Associate in Birkett's Agricultural and Estates team to discuss all things natural capital.
Read moreV@ update - January 2025
Welcome to the January 2025 edition of RPC's V@, our monthly update which provides news and analysis from the VAT world.
Read moreHMRC’s enquiry and correction powers
A key consultation on proposed reforms to HMRC’s enquiry and correction powers closed today. Dubbed the "Tax Administration Framework Review – New Ways to Tackle Compliance", this consultation is the latest in a series aimed at streamlining the UK’s tax system. The goal? To make it easier for taxpayers while enabling HMRC to allocate resources more effectively.
Read moreUpper Tribunal considers when a dividend becomes 'due and payable' for tax purposes
In HMRC v Gould [2024] UKUT 00285 (TCC), the Upper Tribunal dismissed HMRC's appeal and confirmed that an enforceable debt arises when a company pays an interim dividend to one shareholder but not another of the same class.
Read moreHMRC launches new R&D voluntary disclosure platform amid increased enforcement and compliance efforts
HMRC has introduced a new specialist research and development (R&D) voluntary disclosure platform. This development follows a surge in HMRC R&D compliance activity, including a number of high-profile raids and arrests. It is estimated that over £1 billion has been lost to the Exchequer in recent years due to speculative or fraudulent R&D claims, prompting HMRC to take decisive action.
Read moreLoan Charge regime - High Court strikes out taxpayers' Part 8 claims as abuse of process
In allowing HMRC's appeal, the High Court determined that the taxpayers' claims in respect of the Loan Charge should be struck out as an abuse of process.
Read moreUpper Tribunal allows taxpayers' appeals on 'deliberate' behaviour
In the Outram case, the Upper Tribunal overturned the First-tier Tribunal's decision concluding that it had erred in law when deciding that the taxpayers had deliberately filed an inaccurate return without considering the subjective knowledge and intention of the taxpayers concerned.
Read moreWill the UK government's latest measures targeting promoters of tax avoidance and fraud be effective?
In this article, which is based on an article published in Issue 4 2024 of the British Tax Review, Adam Craggs considers whether the UK's latest measures targeting promoters of tax avoidance schemes and tax fraud will be effective.
Read morePreparing for an HMRC dawn raid
How to prepare for a dawn raid by HMRC under the authority of a search warrant issued under the Police and Criminal Evidence Act 1984 (PACE), enabling them to enter and search premises to investigate suspected tax fraud.
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