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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.

Regulatory Radar - Summer 2025

Published on 30 Jun 2025. By Gavin Reese, Partner, Head of Regulatory

Welcome to the Summer 2025 edition of RPC's bi-annual Regulatory Radar – a guide to the key regulatory changes worth having on your radar.

Green claims update: June 2025

Published on 26 Jun 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and Ciara Cullen, Partner, Consumer Brands & Retail Sector Lead and Hettie Homewood , Senior Associate and Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

Welcome to our June 2025 round-up of the key legal and regulatory developments relating to green claims.

Falling Fowl in personal injury claims: the Animals Act 1971, fundamental dishonesty, quantum and forum shopping

Published on 11 Jun 2025. By Gavin Reese, Partner, Head of Regulatory and Sally Lord, Knowledge Counsel – Insurance and Litigation

Whether you're dealing with claims under the Animals Act 1971, fundamental dishonesty, quantum disputes or what forum to choose, Boyd v Hughes [2025] deals with it all. Here we discuss the principles before the court in a claim that arose out of a personal injury claim after a fall from a horse and what it means for personal injury cases going forwards.

Regulatory Radar - quick takes - March 2025

Published on 13 Mar 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.

Regulatory Radar - Winter 2025

Published on 10 Mar 2025. By Gavin Reese, Partner, Head of Regulatory

Welcome to the Winter 2025 edition of RPC's bi-annual Regulatory Radar – a guide to the key regulatory changes worth having on your radar.

Green claims update: February 2025

Published on 27 Feb 2025. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and Ciara Cullen, Partner, Consumer Brands & Retail Sector Lead and Hettie Homewood , Senior Associate and Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

Welcome to our round-up of the key legal and regulatory developments relating to green claims.

The EU Compliance headache you don't know you have? A priority primer on the European Accessibility Act

Published on 31 Oct 2024. By Oliver Bray, Senior Partner, Technology, Media & Entertainment Sector Lead and Hettie Homewood , Senior Associate

It is now less than a year until the EU Accessibility Act (EAA) comes into force, which will require businesses to ensure a range of products (eg smartphones and computers) and services (eg e-commerce services, consumer banking services, and ebooks) are accessible for persons with disabilities.

Seeing the wood for the trees: preparing for new deforestation due diligence rules in the UK and EU

Published on 24 Oct 2024. By Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

The Corporate Sustainability Due Diligence Directive expert briefing

Published on 08 Jul 2024. By Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead and Thomas Jenkins, Of Counsel and Sarah Barrie, Associate

The Corporate Sustainability Due Diligence Directive (CSDDD) was adopted on 24 May 2024 and was published in the Official Journal of the EU on 5 July. It entered into force on 26 July, and will apply to companies from 26 July 2028.

Regulatory Radar - January 2024

Published on 08 Jan 2024. By Gavin Reese, Partner, Head of Regulatory

Hello and welcome to the January 2024 edition of RPC’s bi-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.

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.

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?

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.

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.

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.

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.

The Work Couch Live: Employment Rights Bill - what do employers need to know?

30 Sep 2025

Join our Employment, Engagement, and Equality team for a special live episode of The Work Couch - our popular podcast series that brings employment law to life in a practical, accessible, and commercial way.

Supreme Court upholds that fiduciaries must act with "single-minded loyalty toward their principals (or beneficiaries)"

Published on 22 Apr 2025. By Daniel Parkin, Associate and Zoe Melegari, Senior Associate

In Rukhadze and others v Recovery Partners GP Ltd and another [2025] UKSC 10, the Supreme Court unanimously affirmed the legal test for the account of profits rule (the Profit Rule).

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.

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.

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.

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.

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.

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.

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.

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".

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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).

Taxing Matters: The countdown to failure to prevent fraud is on (Part 3): Looking ahead: further developments for corporate criminal liability

Published on 30 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 issued by 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.

What the 'whistleblower' reward scheme means for tax compliance

Published on 24 Jul 2025. By Adam Craggs, Partner and Head of Tax, Investigations and Financial Crime

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.

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.

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.

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.

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.

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.

Tax Bites - July 2025

Published on 01 Jul 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.

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.

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.