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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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20 May 2022
Issues in Contentious Insolvency Webinar Series
Liquidators are appointed whenever a company is wound up. Banks and other financial institutions often need to deal with liquidators. These interactions can range from (and can turn from) run-of-the-mill document/information requests, to something more contentious, high-profile and high-stake:...
19 May 2022
Do companies have a moral duty to self report to the SFO?
Although Amec Foster Wheeler’s corporate bribery settlement has not introduced any legal obligation to self-report wrongdoing to the Serious Fraud Office, the judgment does encourage companies to seriously consider their moral and ethical duties when deciding whether to do so, argue Herbert Smith...
18 May 2022
Australian Federal Election Workplace and Industrial Relations Survey: Back to the future?
In the lead up to the 2022 Australian Federal Election, our national team ran a series of feedback sessions and surveyed our national clients. The results of our 2022 Federal Election Workplace and Industrial Relations Survey are in.
12 May 2022
Half way to COP27: Are governments delivering on their climate promises?
We are excited to launch our latest report, Halfway to COP27 – a review of governments' ambitions and promises in respect of climate change, six months after the 2021 United Nations Climate Change Conference, commonly referred to as COP26, brought together 120 world leaders to discuss the issue.