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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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25 September 2020
EU Mandatory Human Rights Due Diligence Law Takes Shape
Earlier this year we reported on a European Commission proposal to introduce mandatory human rights due diligence legislation for the EU. The European Parliament's Committee on Legal Affairs has now published a draft report which includes the text of a proposed Directive, giving a sense of the...
24 September 2020
Webinar: Sustainability in Arbitration – Reducing the environmental impact of our disputes
Herbert Smith Freehills and the Campaign for Greener Arbitrations are delighted to invite you to attend our webinar on Sustainability in Arbitration. Environmental sustainability is not a new subject, but is one that is increasingly at the forefront of government and corporate strategy and...
23 September 2020
Catalyst // Webinar Series
As markets move from response to recovery, our focus is shifting too. Looking ahead, we expect the global pandemic to operate as a catalyst, accelerating changes in human behaviour, driving forward scientific and technological advances, and ushering in further digitalisation and some tough choices...
23 September 2020
Catalyst // Podcast Series
As markets move from response to recovery, our focus is shifting too. Looking ahead, we expect the global pandemic to operate as a catalyst, accelerating changes in human behaviour, driving forward scientific and technological advances, and ushering in further digitalisation and some tough choices...
23 September 2020
Podcast: Herbert Smith Freehills and GaffneyCline experts speak on ESG and Decarbonisation with the Oil & Gas Council
In this podcast Tim Pawul of the Oil & Gas Council hosts GaffneyCline's Global Head of Carbon Management, Nigel Jenvey and Herbert Smith Freehills' Global Head of Energy, Lewis McDonald, where they talk about ESG and decarbonisation in the context of oil & gas around the world. In the...
23 September 2020
UK Government plans to strengthen Modern Slavery Act 2015 reporting requirements
The UK Government has published its response to the transparency in supply chains consultation . The response sets out significant new proposals intended to strengthen the Modern Slavery Act 2015 ( MSA ), and in particular the requirement for certain organisations to produce a slavery and human...
23 September 2020
Cyber and data security webinars
Cyber security is a high-ranking board agenda item showing no sign of abating. The regulatory landscape is becoming ever more complex as we strive to respond and mitigate the risks of cyber incidents. In the following webinars we delve into some key developments to help you keep abreast of changes...
23 September 2020
POBLACIÓN: La nueva regulación del trabajo a distancia (ESPAÑA)
El 23 de septiembre de 2020 se ha publicado en el Boletín Oficial del Estado, el Real Decreto-ley 28/2020, de 22 de septiembre (“RDL 28/2020”), de trabajo a distancia, que entrará en vigor a los 20 días de su publicación, en todo aquello que se refiere a la regulación de esta modalidad de trabajo.
23 September 2020
The Italian medicines agency AIFA opens a public consultation on the draft guidelines for the preparation of the dossier supporting a price and reimbursement application
This is the last step before the implementation of the new procedure for the price and reimbursement negotiation set out in the Decree on price and reimbursement negotiation of 2 August 2019. The Italian Medicines Agency (AIFA) has launched a one week public consultation, closing 30 September 2020...
22 September 2020
Lexology Getting the Deal Through – Rail Transport 2021 European Union
Our legal specialists in transport comprising Tom Marshall, John Williams, Patrick Mitchell, Oliver Grabowski, Tim Briggs and Max Kaufman, have contributed to the European Union chapter of Lexology's latest country by country guide on Rail Transport 2021.
22 September 2020
HYDROGEN IN GERMANY
The energy transition is considered a catalyst for the supply of clean, secure and affordable energy in Germany. In the fight against climate change, hydrogen made with renewable electricity (green hydrogen) is increasingly regarded as the solution for the decarbonisation of industry sectors with...
