Search results

Breaking the 'old boys club': financial services face cultural overhaul amid regulatory shifts

Published on 05 Sep 2024. By Victoria Lawman, Trainee Solicitor

The financial services sector, a cornerstone of the UK economy, is facing growing scrutiny over its entrenched 'old boys club' culture. This long-standing environment not only hampers diversity and inclusion efforts but also risks triggering increased regulatory intervention.

Generating competition: What is driving competition regulators to focus on AI?

Published on 14 Aug 2024. By Nicholas McKenzie, Associate

It would be an understatement to say that AI has grown in popularity for businesses and consumers alike and this evolving technology is now expected to contribute an eye-watering $15.7 trillion to the global economy by 2030.

What might the new Labour government mean for UK business?

Published on 18 Jul 2024. By Emily Snow, Trainee Solicitor

On 4 July 2024, the Labour party won a landslide general election victory – its first since 2005. In the run up to the election, Labour billed itself as the party of "wealth creation", with Keir Starmer hailing this his "number one mission." Starmer stated that his plan for growth was “pro-worker and pro-business”.

Las Vegas of the East – Navigating Challenges and Embracing Economic Diversification in Macau

Published on 29 May 2024. By Abbie Cheung, Trainee Solicitor

Digital nomads: the world is your oyster?

Published on 08 May 2024. By Samantha Cheng, Trainee Solicitor

Imagine seeing the world while you work, without having to take time off. That's quite the dream, isn't it?

Trainees take on 2024

Published on 06 Feb 2024. By Dominic Barnes, Trainee Solicitor and Tom Butterfield, Associate and Victoria Lawman, Trainee Solicitor and Abigail Pipkin, Trainee Solicitor and Nicholas McKenzie, Associate and Michael Miles, Trainee Solicitor and Emily Snow, Trainee Solicitor and Emily Twomey, Trainee Solicitor and Mars Yeung, Associate

2023 was a year of change, with the Coronation of King Charles III, COVID-19 finally losing its pandemic status and continued economic and political instability across the globe.

Rumble in the concrete jungle – London as a disputes powerhouse

Published on 23 Jan 2024. By Lucas Johncey, Trainee Solicitor

"London is the most attractive centre for commercial litigation and international arbitration" according to the Law Society's International Data Insights Report 2023.

Advertising Video on Demand – To AVOD or avoid?

Published on 15 Sep 2023. By Niamh Greene, Associate

As most movie and TV streamers can attest to, Subscription Video on Demand services (or 'SVODs') continue to multiply. No need to put the kettle on while the adverts play; SVODs offer consumers an instant, ad-free escape to worlds unknown at just a click of a button.

Listing reforms in the UK: to market, to market?

Published on 19 Jul 2023. By Ali Chowdhry, Associate

The Financial Conduct Authority is proposing wide ranging reforms to the UK's Listings Rules to entice more high growth companies to list in London

Luxury today - go green or go home?

Published on 09 May 2023. By Chloe Shum, Associate

"Sustainability" is the new buzzword in marketing.

Next-gen AI: Disrupting your business?

Published on 11 Apr 2023. By Nicholas McKenzie, Associate

It’s no secret the tech sector is going through a tough time at the moment with the large swathes of layoffs seen in 2022 continuing into 2023. So much so that bespoke trackers now actively monitor the 167,004 (and counting) tech jobs already lost this year.

Trainees take on 2023

Published on 02 Feb 2023. By Lauren Butler, Associate and Tom Butterfield, Associate and Ella Green, Associate and Rory Graham, Associate and Lewis Manning, Associate and Nicholas McKenzie, Associate and Emily Snow, Trainee Solicitor

2022 was a year of extremes, with focus on our longest-reigning Monarch alongside our shortest-serving Prime Minister (and a lettuce).

TGI…Thursday?

Published on 04 Jan 2023. By Megan Grew, Associate

What would you say if I offered you 100% of your salary and you only had to work four days a week? For the employees of 70 companies across the UK, this was their reality for the second half of 2022.

HMRC’s enquiry and correction powers

Published on 23 Jan 2025. By Alexis Armitage, Senior Associate and Sarah Dowding, Senior Associate

A key consultation on proposed reforms to HMRC’s enquiry and correction powers closed today. Dubbed the "Tax Administration Framework Review – New Ways to Tackle Compliance", this consultation is the latest in a series aimed at streamlining the UK’s tax system. The goal? To make it easier for taxpayers while enabling HMRC to allocate resources more effectively.

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.

HMRC launches new R&D voluntary disclosure platform amid increased enforcement and compliance efforts

Published on 20 Jan 2025. By Adam Craggs, Partner and Michelle Sloane, Partner

HMRC has introduced a new specialist research and development (R&D) voluntary disclosure platform. This development follows a surge in HMRC R&D compliance activity, including a number of high-profile raids and arrests. It is estimated that over £1 billion has been lost to the Exchequer in recent years due to speculative or fraudulent R&D claims, prompting HMRC to take decisive action.

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.

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.

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.

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.

Taxing Matters: Deck the halls… with weird and wonderful taxes throughout history

Published on 10 Dec 2024.

In our special Christmas episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by Andrew Hubbard, editor-in-chief of Tolley's Taxation Magazine. From candles to beards, join them as they discuss the most bizarre taxes that have existed throughout British history.

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.

Tax Bites – December 2024

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

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

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.

Taxing Matters: ADR in tax disputes with HMRC's ADR lead, Fiona McRobert

Published on 26 Nov 2024.

In this month's episode of Taxing Matters, Alexis Armitage is joined by HMRC's Alternative Dispute Resolution (ADR) lead, Fiona McRobert, to discuss HMRC's approach to the ADR process, and how tax disputes may be resolved outside the Tax Tribunals and the court system.

V@ update - November 2024

Published on 25 Nov 2024. By Adam Craggs, Partner and Jasprit Singh, Senior Associate

Welcome to the November 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.

Customs and excise quarterly update - November 2024

Published on 25 Nov 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the November 2024 edition of RPC's Customs and Excise Quarterly Update.

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.

How to prepare for an HMRC dawn raid

Published on 20 Nov 2024. By Adam Craggs, Partner

One of the most stressful moments for a business is HMRC officers demanding access to your premises, so it is vital to have plans in place in the event of a dawn raid.

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.

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.

Tax Bites – November 2024

Published on 05 Nov 2024. By Adam Craggs, Partner

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

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.

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'.

V@ update - October 2024

Published on 31 Oct 2024. By Adam Craggs, Partner

Welcome to the October 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.

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.

Taxing Matters: Crystal ball gazing with Jasprit Singh

Published on 22 Oct 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and fellow Senior Associate, Jasprit Singh. Join them as they gaze into their crystal ball and predict what could be on the horizon for taxpayers under the new Labour government.

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.

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.

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).

Tax Bites – October 2024

Published on 01 Oct 2024. By Adam Craggs, Partner

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

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).

V@ update - September 2024

Published on 24 Sep 2024. By Adam Craggs, Partner

Welcome to the September 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.

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.

RPC wins 'Marketing Initiative of the Year' at Legal Business Awards 2024

Published on 18 Sep 2024.

International law firm RPC was named the winner of the 'Marketing Initiative of the Year' at the prestigious Legal Business Awards 2024. This accolade highlights the firm's innovative approach in empowering the tax industry through cutting-edge digital solutions, setting new standards for client service and industry leadership.

Taxing Matters: Taxation of agents' fees in the football industry

Published on 17 Sep 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and Partner, Michelle Sloane, to discuss the latest issues surrounding the taxation of agents' fees in the football industry.

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.

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.

Tax Bites – September 2024

Published on 03 Sep 2024. By Adam Craggs, Partner

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

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.