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Thinking - Blog

Part 2: Top 5 corporate crime compliance trends for the year ahead

Published on 26 Jan 2021.

As we commence a new year in the midst of unprecedented global challenges, here is our take on the key financial crime risk and compliance trends you need to be aware of in 2021.

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Thinking - Blog

Part 1: Top 5 corporate crime enforcement trends for the year ahead

Published on 19 Jan 2021.

As we commence a new year in the midst of unprecedented global challenges, here is our take on the key financial crime risks and trends you need to be aware of in 2021.

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Thinking - Video

Financial CrimeCast: Fidelis Omozuapo

Published on 19 Jan 2021.

Welcome to Financial CrimeCast. In this series, the Centre for Legal Leadership, supported by RPC, talks to leaders in the field of financial crime, compliance and ethics. Guests discuss their career journey, what they have learnt along the way and the financial crime issues they see on the horizon.

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Thinking - Publication

Regulatory update - December 2020

Published on 17 Dec 2020.

Welcome to the December edition of the Regulatory update, which pulls together recent developments from across the UK’s regulators – to help you navigate the regulatory maze.

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Thinking - Video

Financial CrimeCast: Lucille Dolor

Published on 14 Dec 2020.

Welcome to Financial CrimeCast. In this series, the Centre for Legal Leadership, supported by RPC, talks to leaders in the field of financial crime, compliance and ethics. Guests discuss their career journey, what they have learnt along the way and the financial crime issues they see on the horizon.

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Thinking - Video

Financial CrimeCast: Andy McClarron

Published on 03 Dec 2020.

Welcome to Financial CrimeCast. In this series, the Centre for Legal Leadership, supported by RPC, talks to leaders in the field of financial crime, compliance and ethics. Guests discuss their career journey, what they have learnt along the way and the financial crime issues they see on the horizon.

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Thinking - Video

Financial CrimeCast: Amanda Pinto QC

Published on 26 Nov 2020.

Welcome to Financial CrimeCast. In this series, the Centre for Legal Leadership, supported by RPC, talks to leaders in the field of financial crime, compliance and ethics. Guests discuss their career journey, what they have learnt along the way and the financial crime issues they see on the horizon.

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Thinking - Blog

Is the current law on corporate criminal liability about to get more teeth?

Published on 05 Nov 2020.

On 3rd November 2020, the Government published its long-awaited response to its January 2017 call for evidence on the question of reforming the law on corporate liability for economic crime. The Government found the evidence inconclusive overall, so it has asked the Law Commission to draft an Options Paper, to assess how effective the current law is relating to corporate criminal liability and where improvements can be made.

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Thinking - Blog

New SFO guide to DPAs: material change, or confirmation of approach?

Published on 28 Oct 2020.

Last week, the Serious Fraud Office (SFO) published a comprehensive guide to its approach to Deferred Prosecution Agreements (DPAs).

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Thinking - Publication

Regulatory update - October 2020

Published on 22 Oct 2020. By Gavin Reese, Partner, Head of Regulatory

Welcome to the October edition of the Regulatory update, which pulls together recent developments from across the UK’s regulators – to help you navigate the regulatory maze.

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Thinking - Blog

UKCA Marking: Updated Guidance

Published on 16 Sep 2020. By Gavin Reese, Partner, Head of Regulatory and Elinor Sidwell, Associate

As the end of the Brexit implementation period draws closer, the UK Government has sought to clarify the changes that will follow. On 1 September 2020 they published the long-awaited guidance on the use of UKCA marking following the withdrawal of the previously issued advice earlier this year.

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Thinking - Publication

Regulatory update - August 2020

Published on 21 Aug 2020. By Gavin Reese, Partner, Head of Regulatory

Welcome to the August edition of the Regulatory update, which pulls together recent developments from across the UK’s regulators – to help you navigate the regulatory maze.

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Thinking - Publication

Reform of audit industry: it's time to split

Published on 28 Jul 2020. By Davina Given, Partner

Audit has been the subject of intense scrutiny over the past few years in the wake of a series of high-profile business collapses such as Carillion, Patisserie Valerie and Thomas Cook in the UK and, more recently, Wirecard in Germany, and there is no shortage of calls for reform of the audit industry.

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Thinking - Blog

Medical Devices Regulation on the horizon

Published on 09 Jul 2020.

The EU Regulation on Medical Devices 2017/745 (the MDR) had been due to become fully applicable on 26 May 2020.

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Thinking - Blog

SMCR: The tricky implementation phase

Published on 09 Jul 2020.

The Senior Managers and Certification Regime (SMCR) came into force for all financial services firms solo-regulated by the Financial Conduct Authority (FCA) on 9 December 2019. The SMCR replaces the previous APER regime under which the FCA had oversight of the individuals working in the financial services industry. There is a one year implementation period for firms to make the changes required by the SMCR, which expires on 9 December 2020.

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Thinking - Publication

Regulatory Radar 2020/21

Published on 09 Jul 2020.

Welcome to the 2020/21 edition of RPC’s annual Regulatory Radar – a guide to the key regulatory changes worth having on your radar. We hope this will be a useful resource, helping you scan the regulatory horizon and highlight changes that could impact your business.

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Thinking - Publication

Regulatory update - June 2020

Published on 26 Jun 2020. By Gavin Reese, Partner, Head of Regulatory

Welcome to the June edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Blog

COVID-19: The Dairy Sector and Welsh health services granted temporary UK competition law exemptions and the European Commission issues first 'Comfort Letter' to Pharmaceutical Manufacturers

Published on 01 Jun 2020. By Melanie Musgrave, Of Counsel

The UK Government has granted a temporary competition law exemption for certain collaboration within the dairy sector and Welsh health services and the European Commission has published its first 'comfort letter' to allow co-operation to ensure supplies of medicines for COVID-19 patients.

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Thinking - Blog

Regulated Activities Order amendments for the new Bounce Back Loan Scheme

Published on 05 May 2020.

On 1 May 2020, the Financial Services and Markets Act 2000 (Regulated Activities) (Coronavirus) (Amendment) Order 2020 was published and came into force on 4 May 2020.

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Thinking - Publication

Regulatory Roundup Q1 2020

Published on 30 Apr 2020. By Gavin Reese, Partner, Head of Regulatory

Welcome to the Spring edition of the Regulatory Roundup, which aims to pull together the key developments across regulatory regimes – and help you to navigate the maze.

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Thinking - Blog

COVID-19: What is the CMA's current approach to UK merger assessment?

Published on 29 Apr 2020. By Melanie Musgrave, Of Counsel

The CMA has been adapting its working practices to react to the ongoing challenges of a change in working environment that has an impact on almost all businesses.

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Thinking - Publication

Key regulatory guidance following COVID-19 pandemic

Published on 27 Mar 2020. By Gavin Reese, Partner, Head of Regulatory

As the world tackles the COVID-19 pandemic, the UK’s Regulators have published a host of useful guidance that firms should take good note of during this period of uncertainty. While not an exhaustive list, we hope this summary highlights the key obligations and requirements currently being brought in by the Regulators.

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Thinking - Publication

Regulatory update - March 2020

Published on 27 Mar 2020. By Gavin Reese, Partner, Head of Regulatory

Welcome to the March edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Publication

Regulatory update - February 2020

Published on 13 Feb 2020.

Welcome to the February edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Publication

Regulatory update - January 2020

Published on 15 Jan 2020.

Welcome to the January edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Publication

Regulatory update - December 2019

Published on 11 Dec 2019.

Welcome to the December edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Publication

Regulatory update - November 2019

Published on 11 Nov 2019.

Welcome to the November edition of our monthly Regulatory Update, which aims to pull together key developments from the past month across the various UK regulators – and help you to navigate the regulatory maze.

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Thinking - Publication

Regulatory update - October 2019

Published on 10 Oct 2019. By Gavin Reese, Partner, Head of Regulatory

Welcome to the October edition of our monthly Regulatory update, which aims to pull together key developments from across the various UK regulators – and help you to navigate the regulatory maze.

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Event

Tax Take: exploring the UK tax landscape

05 Nov 2025

In collaboration with Temple Tax Chambers, our latest Tax Take webinar series explores the UK tax landscape and key considerations for professionals and business leaders seeking insights into the often-complex world of tax.

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Thinking - Blog

IHT not due on failed EBT arrangement

Published on 23 Oct 2025. By Daniel Williams, Associate

In Tonkin v HMRC [2025] UKFTT 750 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a charge to inheritance tax (IHT) under section 94, Inheritance Act 1984 (IHTA 1984) (charge on participators in a close company), which HMRC considered had arisen as a result of an ineffective employee benefit trust (EBT) arrangement.

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Thinking - Podcast

Taxing Matters: Top tips for tax litigation with Jonathan Davey KC from Wilberforce Chambers

Published on 22 Oct 2025.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Jonathan Davey KC, of Wilberforce Chambers, one of the UK’s leading barristers in commercial chancery work with a particular focus on tax, trusts and property.

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Thinking - Blog

Tribunal confirms its decision on “intangible fixed assets” preventing HMRC from reopening the issue

Published on 16 Oct 2025. By Alexis Armitage, Senior Associate

In Inside Track 3 LLP and Ingenious Film Partners 2 LLP v HMRC [2025] UKFTT 986, the First tier Tribunal (FTT) has issued a further decision in the long running Ingenious film partnerships litigation and has ruled in favour of the taxpayers that its earlier decision had already determined that certain rights held by the LLPs constitute intangible fixed assets for the purposes of Part 8 of the Corporation Tax Act 2009 and that HMRC cannot now reopen that issue.

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Thinking - Blog

Tribunal serves decision on cooking alcohols which leads to HMRC policy change

Published on 09 Oct 2025. By Michelle Sloane, Partner and Jasprit Singh, Senior Associate

In Gourmet Classic Ltd v HMRC [2025] UKFTT 00256 (TC), the First-tier Tribunal ruled that Gourmet's cooking wines (and other similar products), with a strength of 4.8% abv, qualify as foodstuffs and are exempt from excise duty.

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Thinking - Blog

Tribunal grants taxpayer's application for disclosure against HMRC in Kittel appeal

Published on 02 Oct 2025. By Jasprit Singh, Senior Associate

In R Eyre and another v HMRC [2025] UKFTT 461 (TC), the First-tier Tribunal allowed the taxpayers' appeals against HMRC’s decision to assess income tax on the sale of a residential property, finding that the property qualified for principal private residence relief. The tribunal rejected HMRC’s argument that the transaction was an adventure in the nature of trade and found that the property qualified for principal private residence relief.

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Thinking - Publication

Tax Bites - October 2025

Published on 01 Oct 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime 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

HMRC fails to establish "practice generally prevailing" in top-slicing relief dispute

Published on 25 Sep 2025. By Daniel Williams, Associate

In Roger Joye and David Sumners v HMRC [2025] UKFTT 664 (TC), HMRC failed to establish that its flawed method of calculating top-slicing relief was the "practice generally prevailing".

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Thinking - Podcast

Taxing Matters: Wealth management for creatives – navigating financial planning in the entertainment industry

Published on 23 Sep 2025.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Simon Reed, Director and wealth manager at RBC Brewin Dolphin, and head of the Entertainment, Media & Sports client segment in London. Together, they delve into the unique financial challenges faced by clients in the creative industries, including actors, musicians, and digital creators.

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Thinking - Blog

Upper Tribunal allows taxpayers' appeals in EIS case

Published on 18 Sep 2025. By Alexis Armitage, Senior Associate

In Hugh Edward Mark Osmond and Matthew Charles Allen v HMRC [2024] UKFTT 00378 (TC), the Upper Tribunal has reversed the decision of the First-tier Tribunal, concluding that the main purpose of the taxpayers in crystallising Enterprise Investment Scheme relief was not the obtaining of an income tax advantage, even though this may have been its effect.

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Thinking - Blog

COVID voluntary repayment scheme launched – last chance to resolve liability before tougher sanctions apply

Published on 15 Sep 2025. By Michelle Sloane, Partner and Alexis Armitage, Senior Associate

On 12 September 2025, the UK Government launched a time-limited COVID repayment window, allowing individuals and businesses to voluntarily repay financial support received during the COVID-19 pandemic, with no questions asked.

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Thinking - Blog

Tribunal refuses HMRC permission to appeal to the Upper Tribunal against two case management decisions

Published on 11 Sep 2025. By Jasprit Singh, Senior Associate

In BGC Services Holdings LLP v HMRC [2025] UKFTT 700 (TC), the First-tier Tribunal (FTT) refused HMRC permission to appeal against the FTT's earlier case management decisions whereby the FTT refused HMRC's application seeking further and better particulars from the taxpayer and granted the taxpayer's application for HMRC to properly particularise its case.

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Thinking - Blog

Tribunal allows taxpayers’ appeals in principal private residence and trading dispute

Published on 04 Sep 2025. By Daniel Williams, Associate

In R Eyre and another v HMRC [2025] UKFTT 461 (TC), the First-tier Tribunal allowed the taxpayers' appeals against HMRC’s decision to assess income tax on the sale of a residential property, finding that the property qualified for principal private residence relief. The tribunal rejected HMRC’s argument that the transaction was an adventure in the nature of trade and found that the property qualified for principal private residence relief.

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Thinking - Publication

Tax Bites - September 2025

Published on 03 Sep 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime 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

Tribunal orders HMRC to disclose whether it used AI in R&D claims

Published on 26 Aug 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime and Alexis Armitage, Senior Associate

The First-tier Tribunal (General Regulatory Chamber) has ruled in the case of Elsbury v Information Commissioner [2025] UKFTT 915 (GRC) that HMRC must disclose whether, and if so when, it used AI in deciding to reject R&D tax credit claims.

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Thinking - Blog

HMRC’s transformation roadmap: what it means for tax disputes

Published on 21 Aug 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime and Rachael Healey, Partner

On 21 July 2025, the government released HMRC’s long-awaited “transformation roadmap”, setting out its digital-first vision for the future of UK tax administration. The document outlines sweeping changes across HMRC’s processes - promising efficiency, greater use of automation and AI, and a modernised compliance regime.

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Thinking - Blog

HMRC targeting supply chain fraud - are you at risk? What every business needs to know

Published on 19 Aug 2025. By Michelle Sloane, Partner and Alexis Armitage, Senior Associate

HMRC has significantly increased its scrutiny of supply chain integrity as part of its ongoing efforts to tackle fraud, particularly within sectors deemed high risk, such as construction, labour supply, wholesale, and import/export businesses. These sectors are particularly vulnerable due to complex subcontracting chains, cash-based payments, and the use of temporary labour.

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Thinking - Blog

Contentious Tax Quarterly Review – Summer 2025

Published on 14 Aug 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime and Liam McKay, Of Counsel

This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena as well as changes to tribunal procedure.

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Thinking - Blog

Tribunal allows taxpayer's R&D appeal

Published on 07 Aug 2025. By Alexis Armitage, Senior Associate

In Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC), the Tax Tribunal allowed a taxpayer's R&D appeal confirming that HMRC could not issue a discovery assessment because the information provided by the taxpayer to HMRC before the enquiry window closed was sufficient to enable a hypothetical HMRC officer to realise that tax had been under assessed.

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Thinking - Publication

Tax Bites - August 2025

Published on 06 Aug 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime 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

Tribunal allows trustee's appeal in inheritance tax case

Published on 31 Jul 2025. By Jasprit Singh, Senior Associate

In Accuro Trust (Switzerland) SA v HMRC [2025] UKFTT 464 (TC), the First-tier Tribunal (FTT) found that when a non-UK domiciled settlor added assets to an offshore trust and later became UK-domiciled, assets deposited after becoming UK domiciled remain “excluded property” when calculating inheritance tax (IHT).

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