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Contentious Tax Quarterly Review – Summer 2025

Published on 14 Aug 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena as well as changes to tribunal procedure.

Tribunal allows taxpayer's R&D appeal

Published on 07 Aug 2025. By Alexis Armitage, Senior Associate

In Realbuzz Group Ltd v HMRC [2025] UKFTT 493 (TC), the Tax Tribunal allowed a taxpayer's R&D appeal confirming that HMRC could not issue a discovery assessment because the information provided by the taxpayer to HMRC before the enquiry window closed was sufficient to enable a hypothetical HMRC officer to realise that tax had been under assessed.

Tax Bites - August 2025

Published on 06 Aug 2025. 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.

Tribunal allows trustee's appeal in inheritance tax case

Published on 31 Jul 2025. By Jasprit Singh, Senior Associate

In Accuro Trust (Switzerland) SA v HMRC [2025] UKFTT 464 (TC), the First-tier Tribunal (FTT) found that when a non-UK domiciled settlor added assets to an offshore trust and later became UK-domiciled, assets deposited after becoming UK domiciled remain “excluded property” when calculating inheritance tax (IHT).

Taxing Matters: The countdown to failure to prevent fraud is on (Part 3): Looking ahead: further developments for corporate criminal liability

Published on 30 Jul 2025.

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance issued by the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

Financial Crime Time - Your update from RPC: 2025 Q2

Published on 30 Jul 2025. 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.

Lawyers Covered - July 2025

Published on 29 Jul 2025. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and Samantha Cresswell, Associate and Simon Love, Senior Associate and Harriet Keltie, 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 our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

PLC QTRLY - Q2 2025

Published on 24 Jul 2025. 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.

What the 'whistleblower' reward scheme means for tax compliance

Published on 24 Jul 2025. By Adam Craggs, Partner

The UK government has recently announced a new reward scheme will be established later this year to encourage informants to report tax fraud to HMRC. Such a reward scheme has implications for tax compliance.

The countdown to failure to prevent fraud is on (Part 2): What is failure to prevent fraud?

Published on 24 Jul 2025.

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

RPC advises Seraya AQX on its acquisition of SPTel

Published on 21 Jul 2025. By Kenneth Leong, Partner

International law firm RPC advised Seraya AQX, a Tokyo-based digital infrastructure investment platform owned by Seraya Partners, on its acquisition of SPTel, a Singapore-based enterprise fibre network operator.

The countdown to failure to prevent fraud is on (Part 1): A recap on corporate criminal liability

Published on 17 Jul 2025.

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

Tribunal allows taxpayer's appeal in respect of overdrawn director's loan account

Published on 17 Jul 2025. By Daniel Williams, Associate

In Quillan v HMRC [2025] UKFTT 421 (TC) the FTT held that a director's loan was neither written off nor released in the absence of a formal acknowledgment from the company's liquidator.

Tribunal accepts taxpayers' Ramsay argument and allows their appeals

Published on 10 Jul 2025. By Alexis Armitage, Senior Associate

In The Vaccine Research Ltd Partnership & Anor v HMRC [2025] UKFTT 402 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeal, concluding that under the Ramsay principle of statutory interpretation, licence fees received as part of a tax-planning scheme, were neither annual payments nor income not otherwise charged of the partners, within sections 683 or 687 of Income Tax (Trading & Other Income) Act 2005.

HMRC directed by tribunal to issue closure notices

Published on 03 Jul 2025.

In Refinitiv Ltd and others v HMRC [2025] UKFTT 415 (TC), the First-tier Tribunal directed HMRC to issue closure notices on the basis it had failed to meet the burden to keep the relevant enquiries open as ongoing judicial review proceedings do not constitute "reasonable grounds" for not issuing a closure notice.

Tax Bites - July 2025

Published on 01 Jul 2025. 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.

Lawyers Covered - June 2025

Published on 30 Jun 2025. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and Sarah Herniman, Associate and Tom Butterfield, Associate and Victoria Lawman, Trainee Solicitor and Oliver Clarke, Trainee Solicitor

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 our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

Regulatory Radar - Summer 2025

Published on 30 Jun 2025. By Gavin Reese, Partner, Head of Regulatory

Welcome to the Summer 2025 edition of RPC's bi-annual Regulatory Radar – a guide to the key regulatory changes worth having on your radar.

Taxing Matters: When tax advice goes wrong: professional negligence in tax disputes

Published on 26 Jun 2025.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.

Green claims update: June 2025

Published on 26 Jun 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and Ciara Cullen, Partner, Retail & Consumer Sector Lead and Hettie Homewood , Senior Associate and Sophie Tuson, Senior Associate, Environment and Climate Change Practice Lead

Welcome to our round-up of the key legal and regulatory developments relating to green claims.

Upper Tribunal dismisses IR 35 challenge

Published on 26 Jun 2025. By Jasprit Singh, Senior Associate

In George Mantides Ltd v HMRC [2025] UKUT 00124 (TCC), the Upper Tribunal dismissed the company's appeal against an income tax determination and national insurance decision. Whilst the UT set aside the earlier decision of the First-tier Tribunal on the basis that there were errors in the assessment of the hypothetical contract, ultimately it came to the same conclusion that the hypothetical contract was one of employment for the purposes of IR35.

Improving HMRC’s Approach to Dispute Resolution

Published on 19 Jun 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This article considers the recently launched consultation aimed at modernising HMRC’s approach to resolving tax disputes.

No Retreat on UK Digital Services Tax – For Now

Published on 12 Jun 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This blog considers recent speculation concerning the future of the UK's Digital Services Tax in the context of trade negotiations between the UK and the USA.

Falling Fowl in personal injury claims: the Animals Act 1971, fundamental dishonesty, quantum and forum shopping

Published on 11 Jun 2025. By Gavin Reese, Partner, Head of Regulatory and Sally Lord, Knowledge Counsel – Insurance and Litigation

Whether you're dealing with claims under the Animals Act 1971, fundamental dishonesty, quantum disputes or what forum to choose, Boyd v Hughes [2025] deals with it all. Here we discuss the principles before the court in a claim that arose out of a personal injury claim after a fall from a horse and what it means for personal injury cases going forwards.

Generative Artificial Intelligence Risks for Litigation Lawyers

Published on 09 Jun 2025. By Nick Bird, Partner and Cheryl Laird, Senior Associate

In R (on the application of Frederick Ayinde) v The London Borough of Haringey AC-2024-LON-003062 the President of the King's Bench Division (Dame Victoria Sharpe) and Mr Justice Johnson gave judgment in two referrals that had been made under the Hamid jurisdiction. That jurisdiction is the court's inherent jurisdiction to regulate its own procedures and enforce the obligations that lawyers owe to it.

FRC overhauls Investor Stewardship Code for 2026

Published on 06 Jun 2025. By Daniel Parkin, Associate and Zoe Melegari, Senior Associate

On 3 June 2025, the Financial Reporting Council (FRC) published the UK Stewardship Code 2026 that will take effect from 1 January 2026.

FOS to consult on interest - Is 8% too high?

Published on 06 Jun 2025. By Hattie Hill, Associate

On 4 June 2025 the Financial Ombudsman Service (FOS) opened a consultation into the standard interest applied to its awards which has historically been applied at 8%.

Court of Appeal confirms pre-construction costs qualify for capital allowances

Published on 05 Jun 2025. By Daniel Williams, Associate

In Orsted West of Duddon Sands (UK) Ltd and others v HMRC [2025] EWCA Civ 279, the Court of Appeal held that expenditure incurred in designing windfarms and on studies informing the installation could qualify for capital allowances.

Tax Bites - June 2025

Published on 03 Jun 2025. 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.

Lawyers Covered - May 2025

Published on 30 May 2025. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and Katharine Cusack, Partner and Cecilia Everett, Partner and Helen Kerr, Senior Associate and Karl Shortman, Associate and Laura Sponti, 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 our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

Blowing the whistle!

Published on 29 May 2025. By Adam Craggs, Partner

Adam Craggs and Tom Holden consider the US and Canadian 'whistleblower' models in light of the government's plans for a new reward scheme inspired by these, as well as the existing HMRC rewards scheme this initiative will complement.

CAT Collective Proceedings - Summer 2025 update

Published on 28 May 2025. 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).

Contentious Tax Quarterly Review – Spring 2025

Published on 22 May 2025. By Adam Craggs, Partner and Liam McKay, Of Counsel

This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena.

Former England captain's IR35 battle with HMRC ends in a score draw

Published on 15 May 2025. By Alexis Armitage, Senior Associate

In Bryan Robson Ltd v HMRC [2025] TC09408, the First-tier Tribunal considered the IR35 legislation in relation to ex-England footballer Bryan Robson. It found payments made for his ambassadorial role at Manchester United fell within the scope of the IR35 legislation, while payments made to him in respect of his image rights did not.

Taxing Matters: Mental Health Awareness Week: breaking down mental barriers in the mind with Jo Maughan

Published on 13 May 2025.

In this special Mental Health Awareness Week episode of Taxing Matters, host Alexis Armitage welcomes Jo Maughan, career coach and former tax director, to discuss how professionals can manage their critical inner voice and break down mental barriers in their mind.

The EU’s Work Programme 2025 – ePrivacy Reg and AI Liability Directive dropped!

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What are the main takeaways for the tech industry from the European Commission’s Work Programme 2025?

EU Guidance on the AI Act

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

How is the European Commission helping businesses interpret the EU’s Artificial Intelligence Act (AI Act)?

The Online Safety Act: Illegal Harms Codes officially in force, focus now on children

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

What are service providers’ new obligations under Ofcom’s new Codes of Practice on Illegal Harms and its Age Assurance and Children’s Access Guidance?

The UK Government’s consultation on Copyright and AI

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

How is the UK Government considering striking the balance between the protection of copyright in materials and the training of AI?

UK’s new AI Cyber Security Code of Practice

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

How is the UK Government seeking to protect AI systems from growing cyber security threats, in particular in respect of deployable AI systems using GenAI?

UK’s “AI Opportunities Action Plan”

Published on 09 May 2025. By Oliver Bray, Senior Partner, Technology, Media & Telecoms Sector Lead and David Cran, Partner, Head of Disputes

How will the UK Government’s new AI Opportunities Action Plan (Plan) impact businesses?

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Published on 09 May 2025. By Abbey Smith, Associate and Adam Craggs, Partner

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Challenging HMRC's Debt Management Actions - Lessons Learned from Local Fuel Ltd

Published on 08 May 2025. By Michelle Sloane, Partner and Daniel Williams, Associate

Michelle Sloane and Daniel Williams consider when a private law action, rather than judicial review, is appropriate to challenge a decision taken by HMRC's debt management team.

Tax Bites - May 2025

Published on 01 May 2025. 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.

Tribunal allows capital allowances claim for expenditure on construction of a quay wall at the Port of Liverpool 

Published on 01 May 2025. By Jasprit Singh, Senior Associate

In The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC), the First-tier Tribunal allowed the company's claim for capital allowances in respect of expenditure incurred on the construction of a quay wall at a new deep-water container terminal at the Port of Liverpool.

Lawyers Covered - April 2025

Published on 30 Apr 2025. By Will Sefton, Partner, Head of the Lawyers Liability and Regulatory Group and Carmel Green, Partner and Tom Butterfield, Associate and Kerone Thomas, Associate and Simon Love, Senior Associate and Shanice Holder, Associate and Tom Wild, 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 our Lawyers Liability & Regulatory Update, in which we highlight the last month's key developments affecting lawyers and the professional risks they face.

RPC promotes three new Partners and six Of Counsel in latest round of promotions

Published on 30 Apr 2025. By Annabella Chu, Partner and Adam Forster, Partner and Eleanor Harley , Partner and Bryony Howe, Of Counsel and Thomas Jenkins, Of Counsel and Liam McKay, Of Counsel and Emma Wherry, Of Counsel and Christopher Whitehouse, Of Counsel and Matthew Wood, Of Counsel

International law firm RPC has announced the promotion of three new Partners and six Of Counsel, effective 1 May 2025.

PLC QTRLY - Q1 2025

Published on 29 Apr 2025. 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.