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Thinking - Blog

Generative Artificial Intelligence Risks for Litigation Lawyers

Published on 09 Jun 2025. By Nick Bird, Partner and Cheryl Laird, Senior Associate

In R (on the application of Frederick Ayinde) v The London Borough of Haringey AC-2024-LON-003062 the President of the King's Bench Division (Dame Victoria Sharpe) and Mr Justice Johnson gave judgment in two referrals that had been made under the Hamid jurisdiction. That jurisdiction is the court's inherent jurisdiction to regulate its own procedures and enforce the obligations that lawyers owe to it.

Thinking - Publication

Regulatory Radar: quick takes May 2025

Published on 12 May 2025. By Gavin Reese, Partner, Head of Regulatory

Welcome to the latest edition of our bi-monthly Regulatory Radar: quick takes update, which collates the latest developments from across the UK’s regulators.

Thinking - Blog

AI in auditing: Embracing a new age for the profession

Published on 08 Jul 2024.

Artificial Intelligence (AI) is a rather new concept for many (ignoring those versed in 80’s Sci-Fi movies); it’s something many don’t know much about and certainly don’t use in our day-to-day lives (or at least appreciate we are using). However, that’s not the case for everyone. Auditors have long been reaping the benefits of AI, but are auditors just scratching the surface of what AI can offer and what impact will an increased use have on their insurance requirements and claims they face?

Thinking - Blog

EU AI ACT-ion stations

Published on 29 Sep 2023. By Helen Armstrong, Partner and Charles Buckworth, Partner

The EU is forging ahead with its vision for AI. With wrapping up talks on the EU AI Act between the EU governments, the Commission and the parliamentary negotiators imminent, we bring you up to date on the EU's risk based approach, the scope of the Act, a timeline, key points that will form the basis of the discussions and next steps.

Thinking - Blog

What To Know About AI Fraudsters Before Facing Disputes

Published on 29 Aug 2023. By Dan Wyatt, Partner and Christopher Whitehouse, Of Counsel

Fraudsters are quick to weaponise new technological developments and artificial intelligence is proving no exception, with AI-assisted scams increasingly being reported in the news, including most recently one using a likeness of a BBC broadcaster.

Thinking - Blog

The November 2023 AI safety summit and the UK's direction of travel

Published on 29 Aug 2023. By Helen Armstrong, Partner and Charles Buckworth, Partner and Joshy Thomas, Senior Knowledge Lawyer

The government has confirmed that the UK AI safety summit will be held at Bletchley Park on 1 and 2 November 2023.

Thinking - Blog

New developments in AI may put law firms at greater risk of phishing fraud

Published on 28 Apr 2023. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group

As the computing power of Artificial Intelligence continues to grow exponentially, we consider how generative technology may expand the reach of traditional phishing frauds aimed at law firms.

Thinking - Publication

All is not (necessarily) lost: Crypto crime recovery

Published on 30 Jun 2022. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime

With over 2 million people in the UK now holding and using cryptocurrency, and the Chancellor announcing that a government backed non-fungible token ("NFT") is to be issued by the Royal Mint this summer, the market for crypto-assets is expected to continue to grow in the coming months and years; so much so that legislation is planned to implement a new regulatory regime for the crypto market.

Thinking - Blog

FTT prevents HMRC from having two bites of the cherry!

Published on 22 Oct 2014. By Dan Wyatt, Partner

In Lady Henrietta Pearson v HMRC [2014] UKFTT 890 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') concluded that HMRC had "ignored" its previous decision by seeking to reduce the amount of a VAT refund which it had ordered HMRC make to Lady Henrietta Pearson ('the taxpayer').

Thinking - Blog

Non-financial misconduct: how the FCA's new rules could impact acquisitions in financial services

Published on 16 Oct 2025. By Ali Chowdhry, Associate

The FCA's latest proposals on non-financial misconduct (NFM) will add an additional factor to corporate transactions in the financial services sector. With new rules extending the regulatory spotlight to a wider range of firms, acquirers should consider NFM risks and policies as part of their due diligence processes. This development is set to influence risk assessment and post-completion integration, making NFM compliance a concern for buyers and sellers alike.

Thinking - Blog

Guide to understanding PSCs and RLEs

Published on 27 Aug 2025. By Neil Brown, Partner

Under the Economic Crime and Corporate Transparency Act 2023, Companies House will be phasing in requirements for people with significant control (PSCs) and relevant officers of relevant legal entities (RLEs) to have their identity verified with Companies House. Therefore, the identification of a company's PSCs and/or RLEs will be as important as ever before.

Thinking - Blog

New identity verification requirements at Companies House

Published on 27 Aug 2025. By Neil Brown, Partner

From 18 November 2025, Companies House will begin phasing in compulsory identity verification under the Economic Crime and Corporate Transparency Act 2023.

Thinking - Publication

PLC QTRLY - Q2 2025

Published on 24 Jul 2025. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our Q2 2025 quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q1 2025

Published on 29 Apr 2025. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our Q1 2025 quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q4 2024

Published on 23 Jan 2025. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our Q4 2024 quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q3 2024

Published on 15 Oct 2024. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our Q3 2024 quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q2 2024

Published on 31 Jul 2024. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q1 2024

Published on 17 Apr 2024. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q4 2023

Published on 05 Feb 2024. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q3 2023

Published on 12 Oct 2023. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q2 2023

Published on 14 Jul 2023. By Connor Cahalane, Partner - Corporate and Karen Hendy, Partner, Head of Corporate & Commercial and Rosamund Akayan, Senior Knowledge Lawyer

This is our Q2 2023 quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q1 2023

Published on 19 Apr 2023. By Connor Cahalane, Partner - Corporate and Karen Hendy, Partner, Head of Corporate & Commercial and Rosamund Akayan, Senior Knowledge Lawyer

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q4 2022

Published on 02 Feb 2023. By Connor Cahalane, Partner - Corporate and Karen Hendy, Partner, Head of Corporate & Commercial and Rosamund Akayan, Senior Knowledge Lawyer

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q3 2022

Published on 14 Nov 2022. By Connor Cahalane, Partner - Corporate

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q2 2022

Published on 26 Jul 2022. By Connor Cahalane, Partner - Corporate

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

PLC QTRLY - Q1 2022

Published on 13 Apr 2022. By Connor Cahalane, Partner - Corporate

Post-Covid and post-Brexit changes are on the horizon for the UK's public companies. This is the first of our regular updates to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

Thinking - Publication

CAT Collective Proceedings - Summer 2025 update

Published on 28 May 2025. By Chris Ross, Partner and David Cran, Partner, Head of Disputes and Zoe Mernick-Levene, Partner

Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).

Thinking - Publication

CAT Collective Proceedings - Summer 2024 update

Published on 24 Jul 2024. By Chris Ross, Partner and David Cran, Partner, Head of Disputes and Zoe Mernick-Levene, Partner

Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).

Thinking - Blog

The CAT's new approach: I can't afford a carriage (dispute)

Published on 02 Jun 2023. By Chris Ross, Partner

Since the collective proceedings regime in the UK's Competition Appeal Tribunal (CAT) kicked off, a number of carriage disputes have arisen. So-called 'carriage disputes' arise when there are two or more competing proposed class representatives (PCRs) seeking certification (and therefore 'carriage') of overlapping class actions.

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Thinking - Blog

Tribunal confirms caregiver living with parents was eligible for principal private residence relief

Published on 06 Nov 2025. By Alexis Armitage, Senior Associate

In Mark Campbell v HMRC [2025] UKFTT 00867, the First-tier Tribunal upheld the taxpayer’s claim for Principal Private Residence (PPR) relief on the disposal of multiple properties, accepting that the taxpayer qualified under the job-related accommodation rules whilst residing in his parents’ home to care for his father.

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.

Thinking - Publication

Tax Bites - November 2025

Published on 05 Nov 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime and Daniel Williams, Associate

Welcome to November 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

Thinking - Blog

Taxpayer recovers almost 2 million in successful SDLT appeal

Published on 30 Oct 2025. By Jasprit Singh, Senior Associate

In Christian Peter Candy v HMRC [2025] UKFTT 416 (TC), the First-tier Tribunal (FTT) decided that Mr Candy was entitled to bring his claim for stamp duty land tax (SDLT) relief outside the 12-month window for amendments to returns, by relying on paragraph 34, Schedule 10, Finance Act 2003.

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.

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.

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.

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.

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 CIS-Pay Ltd v HMRC [2025] UKFTT 00751 (TC), the First-tier Tribunal (FTT) granted the appellant's application for disclosure of all material within HMRC's possession that might assist the appellant's case or undermine HMRC's case.

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 our October 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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".

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.

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.

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.

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.

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.

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 our September 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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.

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.

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.