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Waning immunity? Government consults on reforming sovereign immunity from tax
By Bezhan Salehy Kirsten Prichard Jones Sarah Shucksmith
Sovereign immunity – the principle that foreign governments and heads of state have immunity from certain taxes including Income Tax,...
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Trending topics from the FFA European Fund Finance Symposium 2022
By Clare Golding Adam Caines
The return of the in person Annual European Fund Finance Symposium to London on 28 June 2022 was marked by a sense of optimism for the...
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Lessons from the crypto-crash: the risks of transacting with blockchains
By Sapheen Meran
The pressure on the cryptocurrency market continues to yield further turmoil, with news of crypto hedge fund Three Arrows Capital’s...
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Private residence relief – an encouraging decision for self-builders
By Thomas Schlee
One of the most widely known features of the UK’s capital gains tax regime is private residence relief, which exempts all capital gains...
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Sanctions enforcement: $30bn of Russians’ assets frozen or seized (and the UK levies a £15,000 fine)
By Neill Blundell Helen Harvey Jessica Arapu
On 29 June 2022, the Russian Elites, Proxies, and Oligarchs (REPO) Task Force, a multi-national group aimed at seizing or freezing the...
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Commission accused of using information requests as “fishing expedition” before EU court
By Ciara Barbu-O'Connor Richard Pepper
Like many agencies, the European Commission increasingly requests large volumes of internal documents for its antitrust investigations...
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Office of Financial Sanctions Implementation: looking to upscale and upskill
By Neill Blundell Helen Harvey Helin Gurel
On Wednesday 22 June, the director of the Office of Financial Sanctions Implementation (“OFSI”), Giles Thomson, speaking to the House of...
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Private debt roundtable part 2: Macro trends and influences
By Jamie Macpherson
Jamie Macpherson, senior counsel in our finance team, joined a discussion hosted by Aztec Group on the impact of the current economic...
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Narrowing the scope of Section 1782 applications
By James Popperwell Nikolas Ireland Jessica Arapu
Under 28 U.S.C. § 1782 (“Section 1782”), US federal district courts may order parties based in the US to provide evidence for “use in a...
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Updated Qualifying Asset Holding Company guidance on the activity condition
By Rhiannon Kinghall Were
HMRC recently updated its guidance on the distinction between trade versus investment in relation to the Qualifying Asset Holding Company...
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Know your fraud: specific fraud risk rather than general red flags are needed to invoke the Quincecare duty
By Lorna Emson Nikolas Ireland James Reid
The Quincecare duty has made the news once again. We recently commented on RBS v JP SPC 4 & another [2022] UKPC 18 and Philipp v Barclays...
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Private debt roundtable part 1: LIBOR changes and transition
By Jamie Macpherson
Jamie Macpherson, senior counsel in our finance team, joined a discussion hosted by Aztec Group on the transition from LIBOR and its...
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New strict liability offence for financial sanctions comes into force today, amongst others
By Neill Blundell Francis Bond Jessica Arapu
Following the Economic Crime (Transparency and Enforcement) Act 2022’s expedited passage through Parliament in March 2022, the Office of...
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UK defers Pillar 2 commencement to 31 December 2023
By Bezhan Salehy Rhiannon Kinghall Were
In a surprise announcement today the UK government has postponed the start date for its Pillar 2 top-up tax rules by nine months to 31...
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Corporate criminal liability: ten options for reform
By Neill Blundell Helen Harvey Max Hobbs
The UK’s Law Commission has published its options paper for reform of corporate criminal liability. This much-anticipated report sets out...
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A more appealing position: changes to applying for permission to appeal
By Sophie Rhind
As a successful party in litigation, content with the outcome of a decision, you would not expect to have to give immediate consideration...
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