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03 June 2020
High Court offers sympathy but no remedy to trustee facing unexpected tax bill
In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as part of a tax scheme, failed to obtain from the High Court (1) an order rescinding her appointment as trustee and/or (2) a declaration that she never became a trustee...
27 May 2020
Tax Treaty Interpretation: The Limits of Fiction
In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not affect how the terms of a bilateral tax treaty should be applied. In particular, the Supreme Court held that although the UK deeming provision in question...
22 May 2020
Court of Appeal considers corporation tax deductibility of ‘derecognised’ derivative contracts
In The Union Castle Mail Steamship Company Ltd v HMRC & Ors [2020] EWCA Civ 547, the Court of Appeal considered whether corporation tax relief was available for losses arising from the “derecognition” of derivative contracts. This derecognition was required for accounting purposes due to a...
14 May 2020
Rapid resolution of domicile disputes: be careful what you wish for
In Henkes v HMRC [2020] UKFTT 7645 (“ Henkes ”), the First-tier (Tax) Tribunal (“ the Tribunal ”) held that (a) it could (and would) determine the taxpayer’s domicile status when determining an application for the closure of a domicile enquiry and (b) its determination of that issue would be...
25 June 2019
The view from Brussels - Can the Backstop be Renegotiated?
Both candidates to be leader of the Conservative Party, and therefore to be UK Prime Minister, have vowed to renegotiate the Withdrawal Agreement and in particular the Protocol on Ireland/Northern Ireland. Meanwhile in Brussels, the EU-27 (meeting in Euro summit format) has just reiterated, again,...
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15 September 2021
International Construction Law Conference 2021
King’s College London, Centre of Construction Law and Dispute Resolution, in collaboration with The Academy of Experts presents International Construction Law Conference 2021 Wednesday 15 September 2021 , held online and in person (restrictions permitting)* at King's College London starting at 09...
22 July 2021
Summary of key EU Merger Control developments
Members of the HSF Brussels competition team have written their annual chapter as a contribution to the latest edition of the highly-regarded Global Competition Review (GCR) EMEA Antitrust Review, which provides a comprehensive summary of key recent EU merger control developments. The publication...
22 July 2021
The future of lending to the oil and gas sector
Intense, continued focus on sustainability has put pressure on the oil and gas sector to openly demonstrate its efforts to effect change across the environmental, social and governance (ESG) spectrum. The sector is still a critical one for energy transition, and for ensuring access to energy in...
21 July 2021
How much detail of potential claims is needed prior to renewal?
When it comes to renewing “claims made and notified” policies (such as D&O insurance and Professional Indemnity), policyholders must be careful to disclose full details of any facts known to them which have the potential to give rise to a claim, otherwise they run the risk of disentitling...
21 July 2021
Inside Arbitration - Issue 12
Inside Arbitration is intended to give our clients a personal insight by sharing with you the perspectives of our international arbitration partners from across the globe. Our articles look at the global landscape for disputes and dispute resolution, commenting on regional trends in particular...
20 July 2021
The Bettor's Verdict – a Herbert Smith Freehills podcast on gambling law
This podcast, hosted by Steven Jacobs , will focus on unwinding the tangled web of US gambling laws past and present, telling the stories of the people affected by this sometimes-impenetrable and often-changing landscape, and providing insight on what will come next.
20 July 2021
Sustainable Lending in Real Estate Finance
Sustainability is now firmly at the top of the agenda, but the term has an enormously wide scope. Mirroring the approach of the bond market, two categories of sustainable loan are developing: sustainability-linked loans, where key performance indicators are used to set sustainability performance...
20 July 2021
Virgin Territory: What are the Implications of Restructuring Plans for Defined Benefit Pension Schemes?
The judgment in Re Virgin Active Holdings Limited [2021] EWHC 1246 has empowered the use of restructuring plans under Part 26A to the Companies Act 2006 (‘RPs’) to compromise the rights of unsecured creditors based on evidence that they would receive little or no return on an insolvency.
19 July 2021
Full Federal Court gives Epic Games the green light to continue in its Australian proceedings against Apple – implications for competition enforcement
The Epic Games ( Epic ) v Apple proceedings are back in action, with the Full Court overturning the primary judge’s stay of the proceedings.
16 July 2021
Federal Ministry of Finance reacts to the ruling of the Fiscal Court of Hesse on cum/cum trades
The German Federal Ministry of Finance has now reacted to the ruling regarding cum/cum-trades of the Fiscal Court of Hesse dated 28 January 2020 by way of two decrees (dated 9 July 2021 which were published today), and amended the previous decrees of 2017 on the "Tax Treatment of Cum/Cum...
15 July 2021
A virtual tour of Australia’s favourite art prize – The Archibald Prize
As a Presenting Partner of the Art Gallery of NSW, and Legal Partner of The Archibald Prize, we are pleased to share with you The Archibald, Wynne and Sulman Prizes exhibition, available online as a 360-degree immersive experience that can be accessed anywhere, anytime. This self-guided visit shows...
15 July 2021
Australian Employment, Industrial Relations and Safety Podcasts
Join our experts as they discuss and share their views on the latest developments we are seeing in the employment, industrial relations and workplace healthy and safety space covering areas such as underpayment compliance, annualised salary provisions, industrial manslaughter laws and what key...
15 July 2021
Australian Employment, Industrial Relations and Safety Webinars
In case you missed it, you can access our previous Employment & IR briefing and Safety Leadership Series webinars below. Join our expert briefings for the latest developments we are seeing in the employment, industrial relations and workplace healthy and safety space. In these short sessions,...