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Thinking - Blog
Generative Artificial Intelligence Risks for Litigation Lawyers
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.
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Thinking - Blog
AI in auditing: Embracing a new age for the profession
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?
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Thinking - Blog
The November 2023 AI safety summit and the UK's direction of travel
The government has confirmed that the UK AI safety summit will be held at Bletchley Park on 1 and 2 November 2023.
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Thinking - Blog
New developments in AI may put law firms at greater risk of phishing fraud
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.
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Thinking - Snapshot
The EU’s Work Programme 2025 – ePrivacy Reg and AI Liability Directive dropped!
What are the main takeaways for the tech industry from the European Commission’s Work Programme 2025?
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Thinking - Snapshot
EU Guidance on the AI Act
How is the European Commission helping businesses interpret the EU’s Artificial Intelligence Act (AI Act)?
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Thinking - Snapshot
The Online Safety Act: Illegal Harms Codes officially in force, focus now on children
What are service providers’ new obligations under Ofcom’s new Codes of Practice on Illegal Harms and its Age Assurance and Children’s Access Guidance?
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Thinking - Snapshot
The UK Government’s consultation on Copyright and AI
How is the UK Government considering striking the balance between the protection of copyright in materials and the training of AI?
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Thinking - Snapshot
UK’s new AI Cyber Security Code of Practice
How is the UK Government seeking to protect AI systems from growing cyber security threats, in particular in respect of deployable AI systems using GenAI?
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Thinking - Snapshot
UK’s “AI Opportunities Action Plan”
How will the UK Government’s new AI Opportunities Action Plan (Plan) impact businesses?
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Thinking - Publication
Regulatory Radar: quick takes May 2025
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.
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Thinking - Blog
EU AI ACT-ion stations
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.
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Thinking - Blog
What To Know About AI Fraudsters Before Facing Disputes
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.
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Thinking - Publication
All is not (necessarily) lost: Crypto crime recovery
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.
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Thinking - Blog
FTT prevents HMRC from having two bites of the cherry!
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').
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Thinking - Publication
Green claims update: June 2025
Welcome to our June 2025 round-up of the key legal and regulatory developments relating to green claims.
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Thinking - Blog
FCA consults on new reporting obligations for (i) incidents and (ii) third party arrangements
On 13 December 2024, the FCA published consultation paper CP24/28 (the CP) on proposals for firms to report on operational incidents and, separately, on material third party arrangements. The CP mirrors similar proposals put forward by the PRA and Bank of England on the same day and is designed to align with current international standards (e.g. the EU Regulation on digital operational resilience (DORA)).
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Thinking - Snapshot
Two years on from the Digital Services Act
How has the European Commission (Commission) enforced the Digital Services Act (DSA) since its inception?
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Thinking - Snapshot
Ofcom rolls out implementation phases for compliance with the Online Safety Act
What is Ofcom’s timeframe for implementation of the Online Safety Act (OSA) and what actions will in-scope services need to take to ensure compliance?
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Thinking - Snapshot
New Safer Phones Bill aims at “making social media less addictive” for young people
How does the Safer Phones Bill intend to protect young people online?
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Thinking - Snapshot
EU publishes draft Code for general-purpose AI models
What measures are proposed by the EU AI Office to regulate general-purpose AI (GPAI) models?
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Thinking - Snapshot
UK’s Digital Regulation Co-operation Forum announces new AI and Digital Hub Pilot
What is the AI and Digital Hub and how can AI innovators use it?
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Thinking - Snapshot
EU designates Apple a gatekeeper for iPadOS but not for iMessage
Can a business avoid being designated a “gatekeeper” under the Digital Markets Act (DMA) even if it satisfies the quantitative criteria under the DMA?
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Thinking - Snapshot
Online Safety Act: Ofcom consults on draft codes to protect children online
What must businesses do to ensure online safety for children under the latest codes of practice published by Ofcom?
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Thinking - Snapshot
What in the AI is going on… April to June 2024
Meta launched its newest generation of its open-source LLM (large language model), Llama 3, which is the technology that powers its AI systems. The launch of Llama 3 signals a step closer to human-like AI that can reason and bestow a memory. OpenAI also discussed plans for its next AI model, GPT-5. Like Llama 3, GPT-5 will see improvements to the model’s planning and reasoning capabilities, going beyond its current capability to deal with discrete tasks. GPT-5 is expected to be released later in the year.
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Thinking - Snapshot
EU AI Act is signed!
What are the core elements of the EU’s Artificial Intelligence Act and how does it impact the regulation of AI systems?
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Thinking - Snapshot
New EU guidelines on mitigating risks for electoral
What are the European Commission’s new guidelines and how do they protect the integrity of electoral processes?
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Thinking - Snapshot
CMA publishes update paper on AI Foundation Models
What is the state of play for the market of AI Foundation Models (FM) and what issues in the market is the Competition and Markets Authority (CMA) most concerned about?
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Thinking - Blog
Telecoms supply agreement excludes "loss of profit" claim under "anticipated profits" liability exclusion (EE v Virgin Mobile)
In line with a number of recent cases, in EE Limited v Virgin Mobile Telecoms Limited [2023] EWHC 1989 (TCC) the courts have shown that parties generally cannot avoid clear wording contained in exclusion clauses in order to recover losses that have been expressly excluded (in this case, loss of profits).
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Thinking - Blog
Rolls-Royce entitled to hit the brakes in dispute over termination of a software services agreement (Topalsson v Rolls-Royce)
In Topalsson GmbH v Rolls-Royce Motor Cars Limited [2023] EWHC 1765 (TCC), the High Court has provided useful guidance on how to determine whether a software implementation timeline agreed by the parties is binding, when implementation is considered complete and in what circumstances failing to complete implementation by the contractual deadlines entitles the customer to terminate the contract.
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Thinking - Blog
A narrow escape – software services provider entitled to rely on single aggregate liability cap (Drax v Wipro)
When it comes to bespoke software development projects, a lot can go wrong. There's risk for the customer such as project delays, software defects, functionality issues and a lack of meeting of minds in terms of project requirements.
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Thinking - Blog
Major overhaul of UK telecoms regulation to go ahead by the end of December 2020
The UK still pushing ahead with implementing wide ranging European regulatory changes, but obligations for many "over the top" providers are likely to be postponed.
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Thinking - Publication
CAT Collective Proceedings - Summer 2025 update
Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).
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Thinking - Publication
CAT Collective Proceedings - Summer 2024 update
Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).
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Thinking - Blog
The CAT's new approach: I can't afford a carriage (dispute)
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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Profile
Thinking - Blog
Tribunal confirms caregiver living with parents was eligible for principal private residence relief
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.
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Event
Tax Take: exploring the UK tax landscape
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 - Publication
Tax Bites - November 2025
Welcome to November 2025 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
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Thinking - Blog
Taxpayer recovers almost 2 million in successful SDLT appeal
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.
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Thinking - Blog
IHT not due on failed EBT arrangement
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
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
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
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
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.
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Thinking - Publication
Tax Bites - October 2025
Welcome to our October 2025 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
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
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
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
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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