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Thinking - Blog

Upper Tribunal considers when a dividend becomes 'due and payable' for tax purposes

Published on 23 Jan 2025. By Daniel Williams, Associate

In HMRC v Gould [2024] UKUT 00285 (TCC), the Upper Tribunal dismissed HMRC's appeal and confirmed that an enforceable debt arises when a company pays an interim dividend to one shareholder but not another of the same class.

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Thinking - Blog

FCA consults on new reporting obligations for (i) incidents and (ii) third party arrangements

Published on 16 Jan 2025. By Mark Crichard, Partner and Nigel Wilson, Of Counsel and Praveeta Thayalan, Knowledge Lawyer

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 - Blog

Loan Charge regime - High Court strikes out taxpayers' Part 8 claims as abuse of process

Published on 16 Jan 2025. By Liam McKay, Senior Associate

In allowing HMRC's appeal, the High Court determined that the taxpayers' claims in respect of the Loan Charge should be struck out as an abuse of process.

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Thinking - Blog

Upper Tribunal allows taxpayers' appeals on 'deliberate' behaviour

Published on 09 Jan 2025. By Alexis Armitage, Senior Associate

In the Outram case, the Upper Tribunal overturned the First-tier Tribunal's decision concluding that it had erred in law when deciding that the taxpayers had deliberately filed an inaccurate return without considering the subjective knowledge and intention of the taxpayers concerned.

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Thinking - Blog

Privacy developments – looking back and looking forward

Published on 19 Dec 2024. By Oliver Bray, Senior Partner and Jon Bartley, Partner and Joe Lippitt, Partner and Praveeta Thayalan, Knowledge Lawyer

In this article, we give you a high-level snapshot of the key data protection and privacy developments in the UK and EU in 2024 as well as developments we anticipate for 2025.

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Thinking - Blog

Will the UK government's latest measures targeting promoters of tax avoidance and fraud be effective?

Published on 19 Dec 2024. By Adam Craggs, Partner

In this article, which is based on an article published in Issue 4 2024 of the British Tax Review, Adam Craggs considers whether the UK's latest measures targeting promoters of tax avoidance schemes and tax fraud will be effective.

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Thinking - Blog

Preparing for an HMRC dawn raid

Published on 12 Dec 2024. By Adam Craggs, Partner

How to prepare for a dawn raid by HMRC under the authority of a search warrant issued under the Police and Criminal Evidence Act 1984 (PACE), enabling them to enter and search premises to investigate suspected tax fraud.

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Thinking - Blog

The EU's Cyber Resilience Act: 10 on the 10

Published on 10 Dec 2024. By Richard Breavington, Partner and Dorian Nunzek, Trainee Solicitor

Today the EU's Cyber Resilience Act (Regulation (EU) 2024/2847) ('CRA') enters into force. The CRA recognises that the continuously evolving world of smart products is frequently challenged by vulnerabilities which can potentially lead to cyber-security incidents. Whilst most of the Act's obligations will not be applicable until three years from now, 10 December is the day when the EU takes a big step towards it's ten-year Cybersecurity Strategy. To mark the occasion, we have outlined ten key points that entities in scope must be aware of in preparation for compliance with the CRA.

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Thinking - Blog

Tribunal strikes out HMRC's application for a tax-related information notice penalty against Paul Baxendale-Walker

Published on 05 Dec 2024. By Jasprit Singh, Senior Associate

In Paul Baxendale-Walker v HMRC [2024] UKUT 00154 (TC), the Upper Tribunal granted an application by the taxpayer, under Rule 8(3)(c) of the Upper Tribunal Procedure (Upper Tribunal) Rules 2008, to strike out HMRC's application seeking a tax-related information notice penalty pursuant to paragraph 50 of Schedule 36, Finance Act 2008.

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Thinking - Blog

Court of Appeal considers HMRC's CIS powers and allows taxpayers' appeals

Published on 28 Nov 2024.

In Beech Developments (Manchester) Ltd & Ors v Commissioners for His Majesty's Revenue and Customs [2024] EWCA Civ 486, the Court of Appeal allowed the taxpayers' appeals, finding that HMRC does have power to issue a direction under Regulation 9(4) of the Construction Industry Scheme Regulations, where the same amount has been subject to a regulation 13 determination.

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Thinking - Blog

Tribunal finds insufficiency in taxpayer's return was not brought about "deliberately"

Published on 21 Nov 2024. By Liam McKay, Senior Associate

In allowing the taxpayer's appeal, the First-tier Tribunal determined that an insufficiency in his return was not brought about deliberately.

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Thinking - Blog

Is an insurer responsible for 'the same damage' as its insured?

Published on 19 Nov 2024. By Will Sefton, Partner and Head of the Lawyers Liability and Regulatory Group and Richard Seymour, Associate

Same Damage and Third Party Rights: unpacking Riedweg v HCC and the 2010 Act

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Thinking - Blog

Digital operational resilience: the UK regulatory landscape

Published on 15 Nov 2024. By Richard Breavington, Partner

Operational Resilience in the supply chain has become an undeniable priority for all financial service providers across the continent.

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Thinking - Blog

Contentious Tax Quarterly Review: November 2024

Published on 14 Nov 2024. By Adam Craggs, Partner

Adam Craggs and Harry Smith of RPC provide a Contentious Tax Quarterly Update discussing recent developments in tax litigation.

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Thinking - Blog

SIPP providers – What's next?

Published on 13 Nov 2024. By Thomas Spratley, Associate and Rachael Healey, Partner

Last week the FCA issued a Dear CEO letter to SIPP operators. The letter is one of many the FCA has sent as follow-ups on the consumer duty (including the most recent letters to lifetime mortgage providers) and is a must read for those in the SIPP sector. The letter highlights the FCA's focus areas of ensuring redress is paid (where the FCA does not consider sufficient progress has been made), "outlier firms" when it comes to holdings in non-standard assets, and implementation of the consumer duty, particularly around distribution strategies/identifying target markets.

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Thinking - Blog

Failure to prevent fraud: key guidance released

Published on 08 Nov 2024. By Sam Tate, Partner and Thomas Jenkins, Senior Associate and Robert Semp, Associate

On 6 November 2024, the Home Office released its much-anticipated guidance on the new failure to prevent fraud offence and the procedures that organisations can implement to prevent associated persons from committing fraud offences. Running to 44 pages, this guidance is crucial as it provides a framework for large organisations to establish effective fraud prevention measures.

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Thinking - Blog

Tribunal finds that mixed-use SDLT rates should be reined in for purchase of property and paddock

Published on 07 Nov 2024.

The Upper Tribunal dismissed HMRC's appeal and confirmed that mixed stamp duty land tax (SDLT) rates applied to the purchase of a property and adjoining paddock where a grazing lease for the latter was granted shortly after completion.

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Thinking - Blog

The new Lithium-Ion Battery Safety Bill: where are we with legislation governing lithium-ion battery safety?

Published on 04 Nov 2024. By Jithma Rukunayake, Senior Associate and Andrew Roper, Partner and Aimee Talbot, Knowledge Lawyer

The new Lithium-Ion Battery Safety Bill underwent its first reading on 6 September 2024. We explain the aims of the bill and consider how it fits with the proposed Product Safety and Metrology Bill.

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Thinking - Blog

Autumn Budget 2024: summary of implications for businesses and individuals

Published on 31 Oct 2024. By Adam Craggs, Partner

Adam Craggs explores the key implications of the Autumn Budget 2024 for businesses and individuals.

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Thinking - Blog

Tribunal allows taxpayer's appeal against information notice

Published on 31 Oct 2024. By Jasprit Singh, Senior Associate

In Sangha v HMRC [2024] UKFTT 00564 (TC), the First-tier Tribunal (FTT) allowed, in part, Mr Sangha's appeal against HMRC's information notice issued under paragraph 1, Schedule 36, Finance Act 2008 as the information was not 'reasonably required' or in his 'possession or power'.

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Thinking - Blog

ClientEarth challenges claims made by BlackRock in its sustainable funds

Published on 28 Oct 2024. By James Wickes, Partner and Catherine Zakarias-Welch, Knowledge Lawyer

Not only are regulators clamping down on greenwashing but, as previously highlighted, ClientEarth, a non-profit international environmental law organisation, also has this issue squarely in its sights.

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Thinking - Blog

Government consults on regulation of Buy-Now Pay-Later products

Published on 25 Oct 2024. By Whitney Simpson, Of Counsel and Lucy Hadrill, Associate

In 2021, HM Treasury announced its intention to regulate certain unregulated buy-now pay-later (BNPL) products in the UK. This followed recommendations made in the Woolard Review which raised concerns about the increased use of BNPL products during the pandemic and the significant risk that these unregulated credit products could cause consumer harm.

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Thinking - Blog

FCA consults on changes to the payments safeguarding regime

Published on 24 Oct 2024. By Whitney Simpson, Of Counsel and Lucy Hadrill, Associate

Under the Payment Services Regulations 2017 (PSRs) and the E-Money Regulations 2011 (EMRs) payment institutions (PIs), electronic money institutions (EMIs), small EMIs and credit unions are required to protect "relevant funds" which they receive when making a payment or in exchange for e-money that has been issued. Current safeguarding requirements are set out in the PSRs and EMRs, with guidance contained in the Financial Conduct Authority's (FCA) Approach Document.

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Thinking - Blog

HMRC's DOTAS application struck out

Published on 24 Oct 2024.

In HMRC v Elite Management Consultancy Ltd (in administration) and Adam Bale [2024] UKFTT 00567 (TC), the First-tier Tribunal (FTT) confirmed that HMRC's DOTAS application was automatically struck out when it failed to serve an authorities bundle on time in breach of an 'unless' order issued by the FTT.

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Thinking - Blog

Tribunal confirms that trading had commenced for the purposes of Entrepreneur's Relief

Published on 17 Oct 2024. By Liam McKay, Senior Associate

In allowing the taxpayer's appeal, the First-tier Tribunal determined that an LLP had commenced trading for the purposes of Entrepreneur's Relief.

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Thinking - Blog

Tribunal confirms principal private residence relief available where development began before sale of land

Published on 10 Oct 2024. By Alexis Armitage, Senior Associate

In the recent Nunn case, the First-tier Tax Tribunal allowed the taxpayer's claim for principal private residence relief, where development on land began before its sale.

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Thinking - Blog

Effective case management before the Tax Tribunal

Published on 03 Oct 2024. By Adam Craggs, Partner and Daniel Williams, Associate

Adam Craggs and Daniel Williams consider the various stages involved in a tax appeal to the First-tier Tribunal (Tax Chamber).

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Thinking - Blog

Growth vs. client care: SRA’s warning on mergers and the risk to public trust

Published on 26 Sep 2024. By Kirstie Pike, Partner and Aimee Talbot, Knowledge Lawyer and Victoria Lawman, Trainee Solicitor

We consider the key takeaways from the SRA's warning notice to firms growing by merger, which urges firms to keep client interests central to their decision-making processes.

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Thinking - Blog

Tribunal allows taxpayer's appeal and confirms that non-residential SDLT rates applied

Published on 26 Sep 2024. By Jasprit Singh, Senior Associate

In Anne-Marie Hurst v HMRC [2024] UKFTT 00540 (TC), the First-tier Tax Tribunal allowed the taxpayer's appeal against HMRC's closure notice, in which HMRC concluded that the residential rate of SDLT was due on the purchase of a property because the sellers had used it as a 'hotel, inn or similar establishment' (HISE).

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Thinking - Blog

First conviction under section 2 CJA 1987 overturned – RPC Analysis

Published on 23 Sep 2024. By Sam Tate, Partner

On 16 September 2024, the first conviction for failure to comply with a notice to provide documents or information required by the Serious Fraud Office ("SFO") was overturned by Judge Nicholas Rimmer at Southwark Crown Court. Although this case was highly fact specific, it may result in a less enthusiastic approach towards pursuing such convictions in the future.

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Thinking - Blog

HMRC's offshore information gathering powers

Published on 19 Sep 2024. By Liam McKay, Senior Associate and Michelle Sloane, Partner

This blog considers HMRC's information gathering powers and, in particular, their application to High Net Worth individuals.

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Thinking - Blog

Tribunal awards costs against HMRC due to its unreasonable conduct

Published on 12 Sep 2024.

In Witton v HMRC [2024] UKFTT 489 (TC) (TCC), the First-tier Tribunal allowed HMRC's applications to amend its list of documents and to admit further evidence, and refused to disbar them from proceedings, but nonetheless awarded the taxpayer his costs due to HMRC's unreasonable behaviour.

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Thinking - Blog

Uncertainty around the mandatory reimbursement cap for APP frauds – a new headache for FI firms and their insurers?

Published on 09 Sep 2024. By James Wickes, Partner and Aimee Talbot, Knowledge Lawyer

New regulations coming on 7 October 2024 will force payment firms to reimburse victims of authorised push payment (APP) fraud up to a set limit. On 4 September 2024, the Payment Systems Regulator (PSR) announced a consultation proposing to set this limit at £85,000, vastly reduced from the previously proposed £415,000 cap. This is a potential headache for insurers as the level of the cap will impact assessment of risk and apportionment of liability between sending and receiving payment firms – and the industry will only have 7 days to prepare.

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Thinking - Blog

Tribunal allows taxpayer's post-cessation trade relief claim as enquiry was out of time

Published on 05 Sep 2024. By Alexis Armitage, Senior Associate

In the recent Dennison case, the FTT allowed the taxpayer's post-cessation trade relief claim as HMRC's enquiry was opened out of time.

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Thinking - Blog

Tribunal allows taxpayer's appeal in part in case concerning deliberate and/or careless errors

Published on 29 Aug 2024. By Jasprit Singh, Senior Associate

In Shaun Harte v HMRC [2024] UKFTT 00493 (TC), the First-tier Tribunal reduced HMRC's assessments to income tax, penalties and VAT. It also considered HMRC's application of the 'presumption of continuity' in relation to deliberate and/or careless errors.

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Thinking - Blog

Contentious Tax August 2024

Published on 22 Aug 2024. By Adam Craggs, Partner

Contentious Tax Quarterly Review - Adam Craggs and Harry Smith examine developments in relation to open justice, access to pleadings and the taxation of carried interest.

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Thinking - Blog

Upper Tribunal confirms that anti-abuse provision in UK/Ireland double tax treaty did not apply

Published on 15 Aug 2024.

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC), the Upper Tribunal held that the anti-abuse rule in the UK/Ireland double tax treaty did not apply to deny the withholding exemption, when a Cayman Islands company assigned the benefit of a debt to an Irish company.

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Thinking - Blog

Further welcome news from the FCA – this time on co-manufacturing

Published on 08 Aug 2024. By Jonathan Charwat, Partner and Lauren Murphy, Senior Associate

Following on from our earlier blog, our review of the FCA's 'Discussion Paper' (DP24/1) continues, this time considering the rules relating to co-manufacturers of insurance products.

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Thinking - Blog

Upper Tribunal confirms it’s the end of the road for HMRC's "fishing expedition"

Published on 08 Aug 2024. By Alexis Armitage, Senior Associate

In the recent Hitchins case, the Upper Tribunal confirmed that it was the end of the road for HMRC's "fishing expedition" and ordered it to close its enquiries.

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Thinking - Blog

Potential deregulation and a pragmatic approach to commercial insurance – welcome news from the FCA

Published on 01 Aug 2024. By Jonathan Charwat, Partner and James Houlihan, Associate

The FCA has published a 'Discussion Paper' (DP24/1) seeking feedback on its rules on commercial insurance including in respect of the types of commercial customers in-scope, co-manufacturing of products and bespoke insurance products.

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Thinking - Blog

Closure notices and the appeals process

Published on 01 Aug 2024. By Adam Craggs, Partner and Liam McKay, Senior Associate

In this article we consider the process by which a taxpayer can bring a protracted HMRC enquiry to and end and appeal against a closure notice issued by HMRC.

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Thinking - Blog

SRA consults the legal sector on proposed changes to their fining framework

Published on 30 Jul 2024. By Will Sefton, Partner and Head of the Lawyers Liability and Regulatory Group and Victoria Lawman, Trainee Solicitor

The SRA is conducting a consultation from the 28 June to 20 September 2024 on their proposed changes to the SRA Fining Guidance. The regulator is seeking feedback in response to the new unlimited fining powers granted under the Economic Crime and Corporate Transparency Act (ECCTA 2023).

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Thinking - Blog

HNWs: Understanding HMRC's Offshore Information Gathering Capabilities

Published on 24 Jul 2024. By Michelle Sloane, Partner and Liam McKay, Senior Associate

Wealthy individuals have long been the focus of a substantial part of HMRC’s compliance activities, but a difficult economic climate together with a looming general election and possible change of government is likely to lead to even greater scrutiny of HNWs by HMRC in the short term.

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Thinking - Blog

Tribunal confirms no tax due on disposal of property held on trust for taxpayer's brother

Published on 18 Jul 2024.

In Raveendran v HMRC [2024] UKFTT 273 (TC), the First-tier Tribunal allowed the taxpayer's appeal against HMRC's discovery assessment in relation to the disposal of a property because it was held on trust for his brother.

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Thinking - Blog

Tribunal confirms loans from remuneration trust were disguised remuneration

Published on 11 Jul 2024. By Liam McKay, Senior Associate

In allowing HMRC's appeal in part, the Upper Tribunal determined that payments received under a remuneration trust scheme were caught by the anti-avoidance provisions in Part 7A of the Income Tax (Earnings and Pensions) Act 2003.

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Thinking - Blog

The Corporate Sustainability Due Diligence Directive expert briefing

Published on 08 Jul 2024. By Sam Tate, Partner and Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead and Thomas Jenkins, Senior Associate and Robert Semp, Associate and Sarah Barrie, Associate and Eve Matthews, 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. This means the law will enter into force 20 days later on 26 July, and will apply to companies from 2027.

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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?

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Thinking - Blog

What does a new Labour government mean for the management liability market?

Published on 05 Jul 2024. By Rachael Healey, Partner and Matthew Watson, Partner and Andrew Oberholzer, Senior Associate and Zoe Melegari, Senior Associate and Kim Wright, Senior Associate

We have a new government and the first Labour government for 14 years. What does it mean for the management liability market? We look at what Labour has promised and with that the areas those in the market will want to consider across directors and officers, employment liability and pensions.

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Thinking - Blog

All change: What will a Labour government mean for financial services?

Published on 05 Jul 2024. By Rachael Healey, Partner and David Allinson, Partner and George Smith, Partner and Matthew Watson, Partner and Andrew Oberholzer, Senior Associate and Heather Buttifant, Associate

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Thinking - Blog

Dealing with HMRC information notices

Published on 04 Jul 2024. By Adam Craggs, Partner and Daniel Williams, Associate

Considering three common types of HMRC information notices and the extent to which they can be challenged.

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