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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.

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

Published on 18 Jul 2024. By Keziah Mastin, Associate

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.

Taxing Matters: Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

Published on 16 Jul 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

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.

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.

Tax Bites – July 2024

Published on 02 Jul 2024. By Adam Craggs, Partner

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

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.

Costly objection by HMRC

Published on 15 Apr 2024. By Harry Smith, Senior Associate

FTT allows costs application where HMRC acted unreasonably in opposing specific disclosure application.

Tax Bites – April 2024

Published on 03 Apr 2024. By Adam Craggs, Partner

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

V@ update - March 2024

Published on 26 Mar 2024. By Adam Craggs, Partner

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

International Women's Day special – Inspiring inclusion with Tax Titan Trio

Published on 08 Mar 2024.

To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.

Tax Bites - February 2024

Published on 07 Mar 2024. By Adam Craggs, Partner

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

V@ update - February 2024

Published on 28 Feb 2024. By Adam Craggs, Partner

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

Customs and excise quarterly update - February 2024

Published on 28 Feb 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

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

A whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC

Published on 21 Feb 2024.

In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

Tax Bites - January 2024

Published on 31 Jan 2024. By Adam Craggs, Partner

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

Exploring the World of AI with Olivia Dhein

Published on 30 Jan 2024.

In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.

V@ update - January 2024

Published on 24 Jan 2024. By Adam Craggs, Partner

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

Tackling "Tax avoidance" this Christmas season with Sam Brodsky

Published on 12 Dec 2023.

As the cost of living crisis bites more than ever this year, in this special Christmas episode of RPC's Taxing Matters, we bring you some Christmas cheer by way of a light-hearted discussion of some of the potential ways you may be able to reduce your tax bill. In addition, we'll also have a quick look at Santa's tax position in the run up to Christmas and whether he might be guilty of tax avoidance … or even tax evasion!