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Thinking - Blog

Government Details Scope for 'Phase One' of Pensions Review

Published on 22 Aug 2024. By Thomas Spratley, Associate

The Government has published its 'terms of reference' for phase one of its wide-ranging review into the UK pensions industry. This development is relevant to those working in the pension industry (actuaries, lawyers, administrators and investment consultants) as well as pension scheme trustees and, with that, their PTL insurers.

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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

SRA introduces new rules to restrict fees recoverable in financial mis-selling claims

Published on 20 Aug 2024. By Ben Simmonds, Associate and Esme Watson, Senior Associate

The SRA has taken steps to bring law firms and CMCs into line through the introduction of a cap on fees solicitors are able to recover from their clients when acting on their behalf in relation to financial mis-selling claims.

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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

Navigating the advice-guidance boundary continued...

Published on 14 Aug 2024. By Ben Simmonds, Associate

In December 2023, the FCA released a Policy Paper (the Paper) which included its proposals for closing the gap between 'holistic advice' and 'information and guidance'. The intention was to "smooth the cliff edge between holistic advice and information and guidance to create a continuum of support." Recent reports indicate that the FCA will shortly be announcing its plan to address this gap.

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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

The BSPS saga: the redress scheme two years later

Published on 05 Aug 2024. By Damien O'Malley, Associate

The Financial Conduct Authority (FCA) has reported that fewer than one third of former British Steel Pension Scheme (BSPS) members deemed to have received unsuitable advice to transfer out have actually received redress following the introduction of the redress scheme under s.404 of FSMA. Of the £49m the FCA anticipated would be paid out through the scheme (this of itself being a revised figure), only £8.7m has so far been paid out to affected members.

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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

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

The road lengthens for vehicle finance complaints - FCA consults on extending timeframes further

Published on 01 Aug 2024. By Haiying Li, Associate and David Allinson, Partner

The FCA has published a consultation paper inviting discussion on a further extension to complaints handling rules for motor finance complaints. This comes as a result of the FCA admitting that it will not be able to set out the next steps they intend to take in this area by the anticipated deadline of 24 September 2024.

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Thinking - Snapshot

UK’s Digital Regulation Co-operation Forum announces new AI and Digital Hub Pilot

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What is the AI and Digital Hub and how can AI innovators use it?

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Thinking - Snapshot

EU designates Apple a gatekeeper for iPadOS but not for iMessage

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

Can a business avoid being designated a “gatekeeper” under the Digital Markets Act (DMA) even if it satisfies the quantitative criteria under the DMA?

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Thinking - Snapshot

Online Safety Act: Ofcom consults on draft codes to protect children online

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What must businesses do to ensure online safety for children under the latest codes of practice published by Ofcom?

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Thinking - Snapshot

What in the AI is going on… April to June 2024

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

Meta launched its newest generation of its open-source LLM (large language model), Llama 3, which is the technology that powers its AI systems. The launch of Llama 3 signals a step closer to human-like AI that can reason and bestow a memory. OpenAI also discussed plans for its next AI model, GPT-5. Like Llama 3, GPT-5 will see improvements to the model’s planning and reasoning capabilities, going beyond its current capability to deal with discrete tasks. GPT-5 is expected to be released later in the year.

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Thinking - Snapshot

EU AI Act is signed!

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What are the core elements of the EU’s Artificial Intelligence Act and how does it impact the regulation of AI systems?

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Thinking - Snapshot

CMA publishes update paper on AI Foundation Models

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What is the state of play for the market of AI Foundation Models (FM) and what issues in the market is the Competition and Markets Authority (CMA) most concerned about?

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Thinking - Snapshot

New EU guidelines on mitigating risks for electoral

Published on 01 Aug 2024. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What are the European Commission’s new guidelines and how do they protect the integrity of electoral processes?

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Thinking - Blog

Closure notices and the appeals process

Published on 01 Aug 2024. By Adam Craggs, Partner and Liam McKay, Of Counsel

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 - Publication

Tax Bites – August 2024

Published on 31 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.

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Thinking - Publication

PLC QTRLY - Q2 2024

Published on 31 Jul 2024. By Connor Cahalane, Partner - Corporate and James Channo, Partner and Karen Hendy, Partner, Head of Corporate & Commercial

This is our regular quarterly update to help our listed company clients and other market participants keep up to date with key developments relevant to issuers on the Main Market and AIM market of the London Stock Exchange.

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Thinking - Publication

Lawyers Covered - July 2024

Published on 30 Jul 2024. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and Caroline Shiffner, Senior Associate and Victoria Lawman, Trainee Solicitor and Helen Kerr, Senior Associate

It can be tough for busy lawyers to find enough time to service clients, make it safely through the regulation obstacle course, win new work and keep up-to-date with developments, but we've got you covered! Welcome to the July edition of our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

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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, 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 - Publication

CAT Collective Proceedings - Summer 2024 update

Published on 24 Jul 2024. By Chris Ross, Partner and David Cran, Partner, Head of Disputes and Zoe Mernick-Levene, Partner

Developments in the UK’s competition collective proceedings regime continue apace with new claims recently issued in the Competition Appeal Tribunal (CAT).

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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, Of Counsel

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 refuses HMRC's application for specific disclosure from taxpayer

Published on 23 Jul 2024. By Jasprit Singh, Senior Associate

In Coopervision Lens Care Ltd v HMRC [2024] UKFTT 00351 (TC), the First-tier Tribunal (FTT) refused HMRC's application for specific disclosure finding that the order sought by HMRC was unclear, disproportionate and inappropriate in the circumstances.

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Thinking - Publication

V@ update – July 2024

Published on 23 Jul 2024. By Adam Craggs, Partner

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

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Thinking - Publication

DORA Watch – June and July 2024

Published on 22 Jul 2024. By Jon Bartley, Partner

As financial entities and ICT service providers undergo the final stages of implementation of the Digital Operational Resilience Act (DORA) requirements into their systems and processes, it is imperative to understand the legal developments and ongoing updates arising from EU Member States as they go through their respective transposition and alignment processes. Through TerraLex - our global legal network, which provides us with access to 22,000 lawyers from highly regarded and carefully vetted law firms stretching more than 120 countries – we have collated legal updates focusing on DORA and its implications in EU jurisdictions.

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Thinking - Blog

Embracing digital change: the new reporting functions for the Financial Reporting Council

Published on 19 Jul 2024. By Heather Buttifant, Associate and George Smith, Partner

The Financial Reporting Council (FRC) has announced two new functions, to better understand its existing market intelligence and to deliver on UK growth and competition. However, following the King's speech this week, and with the industry expecting a new, more powerful regulator in the Audit, Reporting and Governance Authority (ARGA) under this new Labour government, are these new functions simply a steppingstone to wider auditing reform?

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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 - Podcast

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.

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Thinking - Blog

The What, the How, and the Responsibility – Liability of Principals for actions of Appointed Representatives under FSMA s39

Published on 12 Jul 2024. By Alison Thomas, Associate

The Court of Appeal has recently affirmed the views of the lower court on the liability of principals for their appointed representatives' actions in KVB Consultants Limited v Jacob Hopkins McKenzie Limited and others.

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Thinking - Blog

Tribunal confirms loans from remuneration trust were disguised remuneration

Published on 11 Jul 2024. By Liam McKay, Of Counsel

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

FCA Review of Consumer Duty Outcomes Monitoring Across the Insurance Industry

Published on 10 Jul 2024. By Hattie Hill, Associate and Esme Watson, Senior Associate

In this blog we take a look at the FCA's recent review of Consumer Duty outcomes monitoring across the insurance sector.

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Thinking - Publication

New Labour government – what is in store for the UK?

Published on 09 Jul 2024. By Rachael Healey, Partner

We have a new Labour Party government for the first time in 14 years. The new government has already made various announcements, with more set to follow in the coming days, and then we have the King’s Speech on 17 July, when the Labour Party will set out its opening legislative agenda – but what can we expect from the new government impacting services regulated by the Financial Conduct Authority, pensions and accountants?

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Thinking - Blog

The Corporate Sustainability Due Diligence Directive expert briefing

Published on 08 Jul 2024. By Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead and Thomas Jenkins, Of Counsel 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. It entered into force on 26 July, and will apply to companies from 26 July 2028.

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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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Thinking - Publication

Entering the codified world – Code of Conduct for directors

Published on 03 Jul 2024. By Matthew Watson, Partner

The Institute of Directors (IoD) has recently published a consultation paper on a Code of Conduct for Directors (the Code) to assist directors in making better decisions given their increasingly "vital, complex and challenging" roles and responsibilities.

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Thinking - Publication

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.

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Thinking - Publication

Lawyers Covered - June 2024

Published on 28 Jun 2024. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and James Ainsworth, Senior Associate and Karl Shortman, Associate and Aimee Talbot, Knowledge Lawyer

It can be tough for busy lawyers to find enough time to service clients, make it safely through the regulation obstacle course, win new work and keep up-to-date with developments, but we've got you covered! Welcome to the June edition of our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

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Press and Media

Which key regulatory changes will shape the rest of 2024?

Published on 27 Jun 2024. By Gavin Reese, Partner, Head of Regulatory

The current regulatory landscape is dynamic and multifaceted, driven by technological advancements and ESG considerations. With increased scrutiny there's a need for robust compliance frameworks - across various sectors. But what are the most pressing issues?

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Thinking - Publication

Regulatory Radar - June 2024

Published on 27 Jun 2024. By Gavin Reese, Partner, Head of Regulatory

Welcome to the June 2024 edition of RPC’s bi-annual Regulatory Radar – a guide to the key regulatory changes worth having on your radar. We hope this will be a useful resource, helping you scan the regulatory horizon and highlight changes that could impact your business.

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Thinking - Publication

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.

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Thinking - Publication

Financial Crime Time - Your update from RPC: 2024 Q2

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

Welcome to the latest edition of our round-up of news making the headlines in the world of financial crime and compliance. Our aim is to give you an easily digestible, bite-sized overview of issues that are of interest and which may affect your business.

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Thinking - Blog

The Financial Ombudsman Service Proactive Settlement Scheme - Here to Stay

Published on 24 Jun 2024. By Faheem Pervez, Senior Associate

The Financial Ombudsman Service's (FOS) Proactive Settlement Scheme (the Scheme), designed to encourage businesses to settle customer complaints quickly, is here to stay following its trial introduction in April 2023. The Scheme was trialled as a way to encourage early settlement allowing businesses to make a settlement offer in response to complaints referred to the FOS within 21 days, provided they notified the FOS of their intention to do so within 14 days of being told that a complaint had moved to the investigation stage. The FOS has now confirmed that the Scheme will become a permanent feature of their complaint resolution process.

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Thinking - Blog

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

Published on 20 Jun 2024. By Jasprit Singh, Senior 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.

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Thinking - Blog

Another failed FOS judicial review on the issue of whether a customer was an "eligible complainant"

Published on 18 Jun 2024. By Rachael Healey, Partner

The High Court has rejected a judicial review claim arguing that (1) a complainant was not an eligible complainant having identified themselves as an "elective professional client" and (2) the FOS' approach to redress (adopting the FTSE UK Private Investors Income Total Return Index) and contributory negligence was irrational. The High Court judgment is a further example of the courts endorsing FOS' approach to complaints and its wide jurisdiction. The judgment is hot on the heels of the Court of Appeal judgment in Options last month. It is also a further example of permission having been granted to proceed with a judicial review and the increased appetite for respondent firms to challenge FOS, likely to be fuelled by the ever increasing FOS redress caps.

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Thinking - Blog

Tribunal allows entrepreneurs' relief appeal

Published on 13 Jun 2024.

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

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