Taxing Matters

In this episode, Alexis Armitage, Taxing Matters host and Senior Associate at RPC, speaks with Rebecca Sheldon of Old Square Tax Chambers, about the Court of Appeal’s recent decision in A Taxpayer v HMRC, in which Rebecca was instructed on behalf of the taxpayer. The discussion focuses on how "exceptional circumstances" under the Statutory Residence Test (SRT) should be interpreted, particularly where personal and moral obligations are involved. Join Alexis and Rebecca as they discuss:the background of the case and why HMRC challenged the taxpayer’s UK residency statusthe SRT and the meaning of "exceptional circumstances"why the taxpayer's claim under the SRT is of particular interestthe journey of the case through the FTT, the UT and finally the Court of Appealhow the case is relevant for other taxpayers seeking to rely on "exceptional circumstances" in the context of the SRTthe key lessons from the decision for taxpayers and advisors on evidence and planning residency days.Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world.If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Alexis Armitage.All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Jonathan Davey KC, of Wilberforce Chambers, one of the UK’s leading barristers in commercial chancery work with a particular focus on tax, trusts and property. Jonathan shares his practical insights and top tips for navigating the complexities of tax litigation, drawing on decades of experience at the Bar; from keeping cases simple and crafting compelling narratives, to mastering the detail of documentary evidence and knowing when to settle.Whether you are a tax advisor, litigator, or in-house counsel, this episode offers useful tips for anyone involved in tax disputes and litigation against HMRC.If you would like to discuss any of the matters raised in this episode, or find out more about our tax litigation offering, please contact Adam Craggs or Alexis Armitage.All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Simon Reed, Director and wealth manager at RBC Brewin Dolphin, and head of the Entertainment, Media & Sports client segment in London. Together, they delve into the unique financial challenges faced by clients in the creative industries, including actors, musicians, and digital creators.Join Alexis and Simon in this month's episode as they discuss:the complexities of managing unpredictable income streamsthe importance of early wealth planning for creativesworking collaboratively with tax lawyers and accountants on cross-border and residency issuesprotecting and monetising intellectual property (IP)emerging trends in long-term financial planning, including pensions, succession, and philanthropythe rise of new client types in the digital creator economy and their distinct advisory needs.Whether you advise creatives or are part of the entertainment sector yourself, this episode offers practical insights on how to navigate wealth management and maximise after-tax returns in a rapidly evolving industry.Our Tax, Investigations and Financial Crime team advise individuals and businesses on a range of complex tax matters. The team is ranked Band 1 in the Chambers High Net Worth Guide for Tax: Private Client. If you would like to discuss any of the matters raised in this episode, or find out more about our work for high net worth clients, please contact Adam Craggs or Alexis Armitage.  All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Notice from RBC Brewin Dolphin:RBC does not offer tax advice and this does not constitute tax or legal advice. Tax treatment depends on the individual circumstances of each client and may be subject to change in the future.The value of investments, and any income from them, can fall and you may get back less than you investedInformation is provided only as an example and is not a recommendation to pursue a particular strategy. 

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.In this three-part special of RPC's Taxing Matters podcast, RPC's Tom Jenkins, Of Counsel and Financial Crime specialist joins Alexis Armitage, RPC's Taxing Matters podcast host to discuss the new offence and its potential impact on businesses, and other developments relevant to the law of corporate criminal liability.In the final episode of the series, Alexis Armitage and Tom Jenkins discuss the future of corporate criminal liability, focusing on new and upcoming legal developments.In this episode, they discuss:developments regarding “failure to prevent” offences, including bribery, facilitation of tax evasion, and the forthcoming fraud offencethe potential impact of the proposed Crime and Policing Bill, which could significantly broaden corporate liability further, including in relation to non-financial crime offenceskey considerations for organisations in preparation for 1 September 2025, including compliance, training, and risk assessment.All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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.In this three-part special of RPC's Taxing Matters podcast, RPC's Tom Jenkins, Of Counsel and Financial Crime specialist joins Alexis Armitage, RPC's Taxing Matters podcast host to discuss the new offence and its potential impact on businesses, and other developments relevant to the law of corporate criminal liability.In the second episode of our series, Alexis and Tom dive into the new failure to prevent fraud offence, which comes into force in September 2025 under the Economic Crime and Corporate Transparency Act, and discuss:details of the new offence and who it will apply towhich fraud offences are in scopean analysis of its effect on large organisations and smaller businessesjurisdictional scope, including risks for overseas companiesthe “reasonable procedures” defence and six key compliance principleswhat businesses should be doing now in readinessStay tuned for the final episode in our series as we look at what might be coming next in this fast-moving area of the law. All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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.In this three-part special of RPC's Taxing Matters podcast, RPC's Tom Jenkins, Of Counsel and Financial Crime specialist joins Alexis Armitage, RPC's Taxing Matters podcast host to discuss the new offence and its potential impact on businesses, and other developments relevant to the law of corporate criminal liability.Part 1: A recap on corporate criminal liabilityIn part 1, Alexis and Tom look at how the law around corporate criminal liability is changing and discuss:the historic “identification doctrine” and its limitations for law enforcement bodies when seeking to prosecute companieskey criticisms of the old law and why reform was neededthe major changes introduced by the Economic Crime and Corporate Transparency Act, including the new legal test for attributing criminal liability to companieswhat counts as a “senior manager” under that new test and which offences are in scopesteps organisations should consider in response to this important change in the law.Coming soonStay tuned for our next episodes as we take a more in depth look at the new failure to prevent fraud offence, and consider the future of corporate criminal liability. Part 2: What is failure to prevent fraud? | Thursday 24 JulyPart 3: Looking ahead: further developments for corporate criminal liability | Thursday 31 JulyAll information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.