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Thinking - Publication

Take 10 - May 2022

Published on 09 May 2022. By Keith Mathieson, Partner

Welcome to RPC's Media and Communications law update for media lawyers. This month's digest reports on key media developments and the latest cases.

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Thinking - Blog

Interim injunctions and competing public interests (Attorney General v BBC)

Published on 22 Apr 2022. By Mafruhdha Miah, Senior Associate

In Her Majesty's Attorney General for England and Wales v British Broadcasting Corporation [2022] EWHC 826 (QB), an interim injunction has been granted in favour of the Attorney General (AG) to restrain the BBC from broadcasting the identity and image of an alleged covert human intelligence source for MI5 (known only as ‘X’) who is accused of being abusive to two former partners and using his position with MI5 to terrorise and control one of the women. The injunction was granted on the basis that, while it "represented a very significant interference with the right of the BBC to freedom of expression and the correlative right of the public to receive the information the BBC wishes to publish" [23], such a measure was necessary in order to prevent a real and immediate risk to X’s life or safety, as well as the potential wider impact of publication on national security.

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Thinking - Publication

Take 10 #21

Published on 12 Apr 2022. By Keith Mathieson, Partner

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #20

Published on 24 Feb 2022.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #19

Published on 10 Nov 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #18

Published on 10 Oct 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #17

Published on 10 Sep 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #16

Published on 18 Jul 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #15

Published on 20 Jun 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #14

Published on 20 May 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #13

Published on 07 May 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #11

Published on 18 Feb 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #12

Published on 04 Feb 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #10

Published on 22 Jan 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #9

Published on 08 Jan 2021.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #8

Published on 24 Dec 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #7

Published on 04 Dec 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #6

Published on 20 Nov 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #5

Published on 30 Oct 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #4

Published on 16 Oct 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #3

Published on 28 Sep 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #2

Published on 30 Jun 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Thinking - Publication

Take 10 #1

Published on 30 Jun 2020.

Welcome to RPC's media and communications law update. This issue reports on key media developments and the latest cases.

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Service

Media & Content Disputes

Our market-leading media and content disputes team is the largest and most experienced media defence team in the UK.

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Sector

Media & Entertainment

As one of the UK’s strongest media law teams, we work closely with you to tackle any challenges that come your way.

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Thinking - Blog

What the 'whistleblower' reward scheme means for tax compliance

Published on 24 Jul 2025. By Adam Craggs, Partner

The UK government has recently announced a new reward scheme will be established later this year to encourage informants to report tax fraud to HMRC. Such a reward scheme has implications for tax compliance.

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Thinking - Blog

New legislation announced making recruitment agencies or end clients jointly and severally liable for PAYE and NIC

Published on 24 Jul 2025. By Adam Craggs, Partner and Michelle Sloane, Partner and Daniel Williams, Associate

New legislation announced making recruitment agencies or end clients jointly and severally liable for PAYE and NIC

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Thinking - Podcast

The countdown to failure to prevent fraud is on (Part 2): What is failure to prevent fraud?

Published on 24 Jul 2025.

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

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Thinking - Podcast

The countdown to failure to prevent fraud is on (Part 1): A recap on corporate criminal liability

Published on 17 Jul 2025.

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

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Thinking - Blog

Tribunal allows taxpayer's appeal in respect of overdrawn director's loan account

Published on 17 Jul 2025. By Daniel Williams, Associate

In Quillan v HMRC [2025] UKFTT 421 (TC) the FTT held that a director's loan was neither written off nor released in the absence of a formal acknowledgment from the company's liquidator.

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Thinking - Blog

HMRC's latest nudge letter campaign targets loan arrangements

Published on 14 Jul 2025. By Adam Craggs, Partner and Michelle Sloane, Partner

HMRC is targeting taxpayers who have claimed tax relief for interest paid, or other debits relating to loans, where they suspect that one of the taxpayer's "main purposes" for entering into the loan relationship was to avoid tax.

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Thinking - Blog

Tribunal accepts taxpayers' Ramsay argument and allows their appeals

Published on 10 Jul 2025. By Alexis Armitage, Senior Associate

In The Vaccine Research Ltd Partnership & Anor v HMRC [2025] UKFTT 402 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeal, concluding that under the Ramsay principle of statutory interpretation, licence fees received as part of a tax-planning scheme, were neither annual payments nor income not otherwise charged of the partners, within sections 683 or 687 of Income Tax (Trading & Other Income) Act 2005.

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Thinking - Blog

HMRC directed by tribunal to issue closure notices

Published on 03 Jul 2025.

In Refinitiv Ltd and others v HMRC [2025] UKFTT 415 (TC), the First-tier Tribunal directed HMRC to issue closure notices on the basis it had failed to meet the burden to keep the relevant enquiries open as ongoing judicial review proceedings do not constitute "reasonable grounds" for not issuing a closure notice.

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Thinking - Publication

Tax Bites - July 2025

Published on 01 Jul 2025. By Adam Craggs, Partner and Daniel Williams, Associate

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

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Thinking - Podcast

Taxing Matters: When tax advice goes wrong: professional negligence in tax disputes

Published on 26 Jun 2025.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.

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Thinking - Blog

Upper Tribunal dismisses IR 35 challenge

Published on 26 Jun 2025. By Jasprit Singh, Senior Associate

In George Mantides Ltd v HMRC [2025] UKUT 00124 (TCC), the Upper Tribunal dismissed the company's appeal against an income tax determination and national insurance decision. Whilst the UT set aside the earlier decision of the First-tier Tribunal on the basis that there were errors in the assessment of the hypothetical contract, ultimately it came to the same conclusion that the hypothetical contract was one of employment for the purposes of IR35.

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Thinking - Publication

V@ update - June 2025

Published on 20 Jun 2025. By Adam Craggs, Partner and Jasprit Singh, Senior Associate

Welcome to the May 2025 edition of RPC's V@, our monthly update which provides news and insightful analysis from the VAT world.

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Thinking - Blog

Improving HMRC’s Approach to Dispute Resolution

Published on 19 Jun 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This article considers the recently launched consultation aimed at modernising HMRC’s approach to resolving tax disputes.

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Thinking - Blog

No Retreat on UK Digital Services Tax – For Now

Published on 12 Jun 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This blog considers recent speculation concerning the future of the UK's Digital Services Tax in the context of trade negotiations between the UK and the USA.

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Thinking - Blog

Court of Appeal confirms pre-construction costs qualify for capital allowances

Published on 05 Jun 2025. By Daniel Williams, Associate

In Orsted West of Duddon Sands (UK) Ltd and others v HMRC [2025] EWCA Civ 279, the Court of Appeal held that expenditure incurred in designing windfarms and on studies informing the installation could qualify for capital allowances.

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Thinking - Publication

Tax Bites - June 2025

Published on 03 Jun 2025. By Adam Craggs, Partner and Daniel Williams, Associate

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

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Thinking - Blog

New Cryptoasset reporting obligations for businesses

Published on 02 Jun 2025. By Adam Craggs, Partner and Michelle Sloane, Partner and Liam McKay, Of Counsel

The UK is adopting the OECD’s Cryptoasset Reporting Framework (CARF) and expanding it to include domestic data collection and reporting requirements. Starting from 1 January 2026, businesses operating in the cryptoasset sector will face new obligations to collect and report data to HMRC.

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Thinking - Blog

New reporting obligations for Cryptoasset users

Published on 02 Jun 2025. By Adam Craggs, Partner and Michelle Sloane, Partner and Liam McKay, Of Counsel

The UK is adopting the OECD’s Cryptoasset Reporting Framework (CARF) and expanding it to include domestic data collection and reporting requirements. From 1 January 2026, users of cryptoasset service providers will be required to provide identifying information to those providers, which may then be reported to HMRC.

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Thinking - Blog

Blowing the whistle!

Published on 29 May 2025. By Adam Craggs, Partner

Adam Craggs and Tom Holden consider the US and Canadian 'whistleblower' models in light of the government's plans for a new reward scheme inspired by these, as well as the existing HMRC rewards scheme this initiative will complement.

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Thinking - Publication

Customs and excise quarterly update – May 2025

Published on 28 May 2025. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the May 2025 edition of RPC's Customs and excise quarterly update.

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Thinking - Publication

V@ update - May 2025

Published on 28 May 2025. By Adam Craggs, Partner and Jasprit Singh, Senior Associate

Welcome to the May 2025 edition of RPC's V@, our monthly update which provides news and insightful analysis from the VAT world.

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Thinking - Blog

Contentious Tax Quarterly Review – Spring 2025

Published on 22 May 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena.

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Thinking - Blog

Former England captain's IR35 battle with HMRC ends in a score draw

Published on 15 May 2025. By Alexis Armitage, Senior Associate

In Bryan Robson Ltd v HMRC [2025] TC09408, the First-tier Tribunal considered the IR35 legislation in relation to ex-England footballer Bryan Robson. It found payments made for his ambassadorial role at Manchester United fell within the scope of the IR35 legislation, while payments made to him in respect of his image rights did not.

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