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UK cyber security: insure against 'rapid, highly damaging and public' threats
Cyber attacks present a daily threat to UK businesses and have become more destructive in recent years with data breaches and hacks frequently making front page news.
Read moreCourt of Appeal opens the door to 'distress-only' data breach claims where no financial loss
In an important ruling, the Court of Appeal confirms that misuse of private information is a tort and rules on the meaning of "damage" under s13 of the Data Protection Act ("the DPA"), allowing claimants to recover compensation for "distress" resulting from a breach of the Act without also having to prove pecuniary losses.
Read moreSupreme Court clarifies the limits on contractual discretion
A recent decision of the Supreme Court1 has confirmed that the limits on contractual discretion include a requirement to take relevant issues into account and that the discretion is not exercised irrationally.
Read moreCMA call for information on use of online reviews
Online reviews: love them or hate them, there is no escape. Products, services, large multinationals, SMEs, online or offline, almost everyone is being judged these days.
Read moreICO fines online travel insurer £175,000 for failing to keep customers’ personal information secure
The Information Commissioners Office (the “ICO”) has fined Staysure.co.uk Limited (“Staysure”), an online travel insurance company, £175,000 for its failure to comply with the seventh data protection principle, after IT security failings allowed hackers to access up to 100,000 customer financial records.
Read moreNew powers to audit NHS authorities' data protection compliance
From 1 February 2015, the ICO will be able to subject public healthcare organisations to compulsory audits of their data protection compliance under section 41A of the Data Protection Act 1998.
Read moreNew UK Procurement Rules Published for Consultation
Draft new Public Contracts Regulations 2015 and a Consultation Document on UK Transposition of the new EU Procurement Directives have recently been published by the Cabinet Office. This paves the way for the 2014 Directives to be implemented in the UK early next year.
Read moreFCA COMPLETES THEMATIC REVIEW OF MOBILE BANKING AND PAYMENTS
The Financial Conduct Authority (FCA) has recently published its findings following its thematic review of mobile banking and payments.
Read moreEU Consultation on Cloud Computing and Software
The EU has opened a public consultation to help define future research priorities in the areas of Cloud Computing and Software (including Open Source). Any and all stakeholders are invited to submit their views by 10 October 2014.
Read moreUpper Tribunal confirms that anti-abuse provision in UK/Ireland double tax treaty did not apply
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.
Read moreUpper Tribunal confirms it’s the end of the road for HMRC's "fishing expedition"
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.
Read moreClosure notices and the appeals process
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.
Read moreTax Bites – August 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreHNWs: Understanding HMRC's Offshore Information Gathering Capabilities
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.
Read moreV@ update – July 2024
Welcome to the July 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.
Read moreTribunal confirms no tax due on disposal of property held on trust for taxpayer's brother
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.
Read moreTaxing Matters: Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships
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.
Read moreTribunal confirms loans from remuneration trust were disguised remuneration
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.
Read moreDealing with HMRC information notices
Considering three common types of HMRC information notices and the extent to which they can be challenged.
Read moreTax Bites – July 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreV@ update – June 2024
Welcome to the June 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.
Read moreTribunal awards taxpayer his costs due to HMRC's unreasonable conduct
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.
Read moreTribunal allows entrepreneurs' relief appeal
In Cooke v HMRC [2024] UKFTT 272 (TC), the FTT allowed the taxpayer's appeal against HMRC's refusal of entrepreneurs' relief
Read moreExploring tax from an ESG perspective
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.
Read moreTax Bites – June 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal dismisses HMRC's appeal and confirms transactions did not give rise to a taxable remittance
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.
Read moreKey features of the new non-UK domicile regime
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.
Read moreV@ update – May 2024
Welcome to the May 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.
Read moreCustoms and excise quarterly update - May 2024
Welcome to the May 2024 edition of RPC's Customs and Excise Quarterly Update.
Read moreThe latest on the loan charge scandal with Matt Hall from Armadillo
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".
Read moreTaxpayers' application for protective costs order against HMRC refused
UT dismisses taxpayer's application for a protective costs order against HMRC.
Read moreNo bouncing back for directors
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.
Read moreContentious Tax Update
Harry Smith and Adam Craggs examine developments in relation to DOTAS, R&D enquiries, and the Economic Crime and Transparency Act.
Read moreTribunal allows taxpayer's appeal in R&D case against penalty assessment for careless inaccuracy
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.
Read moreTax Bites – May 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreContentious tax quarterly: Spring review
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.
Read moreChanges to non-domiciliary rules with Philip Simpson KC and Ben Symons
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.
Read moreV@ update – April 2024
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.
Read moreCostly objection by HMRC
FTT allows costs application where HMRC acted unreasonably in opposing specific disclosure application.
Read moreTax Bites – April 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreV@ update - March 2024
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.
Read moreInternational Women's Day special – Inspiring inclusion with Tax Titan Trio
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.
Read moreTax Bites - February 2024
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - February 2024
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.
Read moreCustoms and excise quarterly update - February 2024
Welcome to the February 2024 edition of RPC's Customs and Excise Quarterly Update.
Read moreA whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC
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.
Read moreTax Bites - January 2024
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreExploring the World of AI with Olivia Dhein
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.
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