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The government-backed Coronavirus Business Interruption Loan Scheme

Published on 30 Mar 2020.

The Coronavirus Business Interruption Loan Scheme (CBILS) is part of a package of temporary measures to support businesses during these challenging times. The CBILS is intended to give lenders confidence to continue to provide finance to SMEs.

COVID-19 forces HMRC to temporarily change its stamp duty processes

Published on 26 Mar 2020. By Ben Roberts, Partner

Yesterday (25th March) HMRC announced some "temporary" changes to its stamp duty processes, in light of the Covid-19 pandemic.

COVID-19 and Commercial Tenants' Rights Regarding Rent

Published on 25 Mar 2020. By Elizabeth Alibhai, Partner

This blog sets out various issues for commercial tenants to consider in relation to impending rent payments and government intervention in response to Covid-19. We are currently fielding numerous enquiries from tenants seeking advice about whether rent holidays, reductions and other concessions can be obtained in these unprecedented times.

Spring Budget 2020 - main tax announcements

Published on 19 Mar 2020. By Ben Roberts, Partner

This blog discusses some of the key tax changes announced in last week's Budget, and subsequent tax developments.

Signing documents during COVID-19

Published on 18 Mar 2020. By Neil Brown, Partner

This blog gives some practical advice on how to sign documents during the Covid-19 restrictions, including where signatories and others are working from home without access to usual printing and scanning facilities.

Navigating the dead zone: Understanding liquidation preferences in venture capital #2

Published on 16 Mar 2020.

In the second of a series of blogs aimed at demystifying common provisions found in venture capital term sheets (with the hope of accelerating the negotiation process between investors and founders), Peter Sugden looks at liquidation preferences.

Restrictive covenants in shareholders' agreements and commercial contracts

Published on 06 Mar 2020. By Ben Magahy, Senior Associate

The Court of Appeal has recently reaffirmed the approach to the enforceability of restrictive covenants in shareholders' agreements and other commercial contracts.

Life Expectancy - What's the Big Deal?

Published on 21 Feb 2020.

The Prudential Regulation Authority (PRA) has updated its guidance for insurers participating in longevity risk transfers (PS1/20 and SS18/16), clarifying the risks that should be considered and its expectations of pre-notification for transactions that are large and/or complex.

UK formally leaves EU - practical matters you ought to be thinking about now

Published on 07 Feb 2020.

The UK formally left the EU on 31 January 2020. This is not the end, or the beginning of the end, it is the end of the beginning. The much more important future relationship needs to be determined. There is a hiatus until 31 December 2020 when nothing changes with regard to free trade and movement of people between the UK and the EU.

New year's (tax) resolutions

Published on 21 Jan 2020. By Ben Roberts, Partner

It's that time of year when people are abiding by, (re)assessing and / or breaking their new year's resolutions. It's no different in the world of tax.

Equitable Life – High Court approves Part VII transfer, and distinguishes Prudential/Rothesay

Published on 06 Jan 2020. By Neil Brown, Partner

The High Court has approved a large Part VII transfer by Equitable Life of life assurance and pensions policies, and has easily distinguished the decision in Prudential/Rothesay.

Corporate governance for large private companies

Published on 14 Oct 2019. By Nneka Ezekude, Trainee Solicitor

For financial years beginning on or after 1 January 2019, large private companies will need to adhere to the requirements contained in a new corporate governance code published by the Financial Reporting Council. The introduction of the new code followed multiple scandals which revealed poor corporate practices and neglect of stakeholders' interests. As a result, the code seeks to rebuild confidence and trust in these large private companies.

Football, the beautiful investment game?

Published on 17 Sep 2019.

Another football season is upon us and we dream of silverware to be won. However, planning for the next transfer window begins almost immediately for those clubs listed on a stock market. There are opportunities to increase their share price through new signings, managers and sponsorship deals.

'Green Finance' enters the mainstream

Published on 25 Jun 2019. By Edward Colville, Partner

With the UK's recent commitment to cut emissions to net zero by 2050, the financial sector is looking to 'green finance' to encourage investment in sustainable and environmentally-friendly businesses. Recent examples, like Nokia's €1.5 billion credit facility announced last week, show that environmental impact is becoming a key consideration for lenders and borrowers.

National Security and Investment – the EU's response

Published on 07 Jun 2019. By Tim Anderson, Partner and Neil Brown, Partner

National security concerns regarding Huawei continue to make headlines around the world, against the backdrop of an ongoing US / Chinese trade war. This blog looks at new EU rules on foreign investments which raise security or public order concerns.

More than you bargained for: the implied duty of good faith

Published on 26 Apr 2019. By David Wallis, Partner and Neil Brown, Partner

The recent High Court decision in Bates v. Post Office (No. 3) confirms a general principle that if a contract is a "relational" contract then it will include an implied obligation of good faith. Previously, there had been doubt whether such a general principle exists, as historically this was not an approach recognised by the English courts.

Derivative transactions – the obligation to report

Published on 25 Apr 2019. By Edward Colville, Partner

As the recent £34.9m fine for Goldman Sachs shows, the FCA takes the obligation to report derivative transactions seriously. How does this affect parties who trade infrequently, and what changes to the reporting requirement can we expect post-Brexit?

Brexit delay prolongs uncertainty for insurers

Published on 12 Apr 2019. By Neil Brown, Partner

Yesterday's announcement of Halloween as the new deadline for Brexit will prolong uncertainty for many UK insurers.

UK property – big tax changes for non-UK residents

Published on 05 Apr 2019. By Ben Roberts, Partner

From 6 April 2019, all gains from UK real estate realised on disposal by non-residents, whether residential or commercial property and whether by way of direct or "indirect" disposal, will be subject to UK capital gains tax or corporation tax.

A licence to kill... a licence

Published on 11 Mar 2019. By Tim Anderson, Partner

In the second of a number of short articles we are producing in relation to businesses in the tech space, we will be discussing a real life example of what not to do when diligencing a tech company and its third party IP licence agreements.

Part Three: Five practical implications of side letters and most favoured nations clauses for fund investors and managers

Published on 15 Feb 2019.

In this third and final part of our series on side letters and most favoured nation (MFN) clauses in private equity funds, we examine five practical implications for investors and managers.

Part Two: Side letters and fundraising

Published on 28 Jan 2019.

In this second of a three part series, we look more closely at side letters and most favoured nation (MFN) clauses in the private equity space.

Part One: Overview of side letters & MFNs when investing in private equity funds

Published on 14 Jan 2019.

In the first of a three part series we consider the importance of side letters and most favoured nations (MFN) clauses in private equity funds.

New regulations to permit assignment of receivables under commercial contracts now in force

Published on 11 Jan 2019. By Edward Colville, Partner

After more than four years of consultation, draft regulations and revisions, the Business Contract Terms (Assignment of Receivables) Regulations 2018 (the Regulations) have now taken effect, and apply to all relevant contracts entered into on or after 31 December 2018.

Huawei and UK National Security - A new technology cold war?

Published on 11 Dec 2018. By Neil Brown, Partner and Charles Buckworth, Partner

Chinese technology giant, Huawei, has been making plenty of headlines recently. First, a number of Western governments (including the US, Australia and New Zealand) have banned Huawei equipment from being used in 5G networks, citing national security concerns. Next, Huawei's CFO was arrested in Canada in connection with alleged breaches of international sanctions.

Budget 2018 – 10 key business tax takeaways

Published on 08 Nov 2018. By Ben Roberts, Partner

Something out of the ordinary (share capital)

Published on 05 Nov 2018. By Ben Roberts, Partner

The term ordinary share capital is widely used in UK tax provisions. While the term has a statutory definition a recent table by the Chartered Institute of Taxation shows how HMRC has interpreted it in practice.

Tech talent: To purchase or to hire…that is the question

Published on 02 Nov 2018.

When acquiring tech companies & their human talent, there are some key considerations that buyers should take into account when formulating their M&A strategy

Drafting: you do the maths

Published on 01 Nov 2018. By Neil Brown, Partner

Chartbrook v. Persimmon provides a good example of why contracts can benefit from worked mathematical formulae to aid courts in interpreting key contractual clauses.

Managing expectations: key considerations for early stage start-ups and their investors

Published on 30 Oct 2018.

Peter Sugden discusses "good leaver / bad leaver" provisions in early-stage venture capital investment to help explain key terms for start-up business.

Taxpayer's appeal against refusal of CGT loss relief claim allowed

Published on 27 Jun 2024. By Alexis Armitage, Senior Associate

Tax Tribunal confirms CGT relief for loan to trader not prevented by capitalisation of loan.

V@ update – June 2024

Published on 26 Jun 2024. By Adam Craggs, Partner

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

Tribunal awards taxpayer his costs due to HMRC's unreasonable conduct

Published on 20 Jun 2024. By Jasprit Singh, Associate

In Aftab Ahmed v HMRC [2024] UKFTT 00236 (TC), the First-tier Tribunal granted the taxpayer's application for costs as HMRC had acted unreasonably in defending the appeal.

Tribunal allows entrepreneurs' relief appeal

Published on 13 Jun 2024. By Keziah Mastin, Associate

In Cooke v HMRC [2024] UKFTT 272 (TC), the FTT allowed the taxpayer's appeal against HMRC's refusal of entrepreneurs' relief

Exploring tax from an ESG perspective

Published on 07 Jun 2024.

In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

What happens in an HMRC criminal investigation

Published on 06 Jun 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Tax Bites – June 2024

Published on 05 Jun 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 dismisses HMRC's appeal and confirms transactions did not give rise to a taxable remittance

Published on 30 May 2024. By Liam McKay, Senior Associate

In dismissing HMRC's appeal, the Upper Tribunal confirmed that transactions entered into by the taxpayers for the sale of shares did not amount to a taxable remittance under section 809L of the Income Tax Act 2007 because no service was provided in the UK.

Key features of the new non-UK domicile regime

Published on 29 May 2024. By Michelle Sloane, Partner and Jasprit Singh, Associate

The UK government's unexpected announcement in Spring Budget in March on the taxation of non-domicile individuals has sparked concerns and much comment. It represents a major change to the current system of taxation, which is more than 200 years old.

V@ update – May 2024

Published on 28 May 2024. By Adam Craggs, Partner

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

Customs and excise quarterly update - May 2024

Published on 21 May 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

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

The latest on the loan charge scandal with Matt Hall from Armadillo

Published on 21 May 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".

Taxpayers' application for  protective costs order against HMRC refused

Published on 20 May 2024. By Alexis Armitage, Senior Associate

UT dismisses taxpayer's application for a protective costs order against HMRC.

No bouncing back for directors

Published on 20 May 2024. By James Wickes, Partner and Adam Craggs, Partner and Catherine Zakarias-Welch, Knowledge Lawyer

Banned! Fraudsters! – Terms used by the Insolvency Service for directors who abused the government backed loan scheme which was put in place to help businesses struggling during the pandemic.

Contentious Tax Update

Published on 16 May 2024. By Harry Smith, Senior Associate and Adam Craggs, Partner

Harry Smith and Adam Craggs examine developments in relation to DOTAS, R&D enquiries, and the Economic Crime and Transparency Act.

Tribunal allows taxpayer's appeal in R&D case against penalty assessment for careless inaccuracy

Published on 03 May 2024. By Jasprit Singh, Associate

In H & H Contract Scaffolding Ltd v HMRC [2024] UKFTT 00151 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty assessment as the inaccuracy in the tax return was not careless.

Tax Bites – May 2024

Published on 01 May 2024. By Adam Craggs, Partner

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

Contentious tax quarterly: Spring review

Published on 01 May 2024. By Adam Craggs, Partner and Harry Smith, Senior Associate

The last few months have seen a flurry of activity in relation to the DOTAS regime, with HMRC seeking to register arrangements retrospectively and apply substantial penalties for failure to register. Woes continue for those unfortunate enough to have R&D claims under enquiry, and the Economic Crime and Corporate Transparency Act 2023 gives HMRC a significant new tool in relation to suspected criminal activity by bodies corporate and partnerships.

Changes to non-domiciliary rules with Philip Simpson KC and Ben Symons

Published on 30 Apr 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers, to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.

V@ update – April 2024

Published on 24 Apr 2024. By Adam Craggs, Partner

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