In this festive edition of Taxing Matters, RPC’s Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Philip Simpson KC of Old Square Tax Chambers, well known VAT expert and part-time stand-up comedian. Together, they embark on an insightful sleigh ride through the VAT implications of classic Christmas fare, decorations, and traditions, demystifying which seasonal treats and trimmings may attract HMRC’s attention.

From turkey and pigs in blankets, to mince pies and cheese boards, this special episode looks at the tax treatment of festive favourites.

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.

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In this episode of Taxing Matters, Alexis Armitage, Senior Associate in RPC’s Tax Disputes team, is joined by Jivaan Bennett of Temple Tax Chambers. Jivaan brings nearly 15 years of international experience in tax, commercial transactions, and disputes, having worked across the Caribbean, London, and New York.

Together, Alexis and Jivaan discuss the complexities of tax deed claims in the context of corporate transactions, offering practical insights for both lawyers and businesses. Key topics covered in this episode, include:

·      the definition and purpose of tax deeds, and their distinction from tax warranties

·      strategic considerations for making and defending tax deed claims

·      common drafting issues and the importance of clear contractual language

·      the interaction between tax deed claims and tax authority inquiries

·      recent trends, including increased use of arbitration and insurance.

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.

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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 status
• the SRT and the meaning of "exceptional circumstances"
• why the taxpayer's claim under the SRT is of particular interest
• the journey of the case through the FTT, the UT and finally the Court of Appeal
• how the case is relevant for other taxpayers seeking to rely on "exceptional circumstances" in the context of the SRT
• the 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.

Hosted on Acast. See acast.com/privacy for more information.

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.

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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 streams
• the importance of early wealth planning for creatives
• working collaboratively with tax lawyers and accountants on cross-border and residency issues
• protecting and monetising intellectual property (IP)
• emerging trends in long-term financial planning, including pensions, succession, and philanthropy
• the 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 invested
• Information is provided only as an example and is not a recommendation to pursue a particular strategy. 

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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 offence
• the potential impact of the proposed Crime and Policing Bill, which could significantly broaden corporate liability further, including in relation to non-financial crime offences
• key considerations for organisations in preparation for 1 September 2025, including compliance, training, and risk assessment.
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All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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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 to
• which fraud offences are in scope
• an analysis of its effect on large organisations and smaller businesses
• jurisdictional scope, including risks for overseas companies
• the “reasonable procedures” defence and six key compliance principles
• what businesses should be doing now in readiness

Stay 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.

Hosted on Acast. See acast.com/privacy for more information.

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 liability

In 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 companies
• key criticisms of the old law and why reform was needed
• the major changes introduced by the Economic Crime and Corporate Transparency Act, including the new legal test for attributing criminal liability to companies
• what counts as a “senior manager” under that new test and which offences are in scope
• steps organisations should consider in response to this important change in the law.

Coming soon

Stay 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 July
• Part 3: Looking ahead: further developments for corporate criminal liability | Thursday 31 July

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.

Together, they consider where advisers, particularly lawyers and accountants, face exposure to negligence claims, as they discuss:

• the typical lifecycle of a tax dispute
• common scenarios where negligence may occur
• how courts assess negligence
• the role of insurers in professional negligence cases
• practical tips for advisers, lawyers, and insurers to prevent negligence

Whether you are a tax adviser or insurer, this episode offers insights into how tax advice can go wrong, and how to safeguard against it.

If you would like to discuss any of the matters raised in this episode, 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.

Hosted on Acast. See acast.com/privacy for more information.

In this special Mental Health Awareness Week episode of Taxing Matters, host Alexis Armitage welcomes Jo Maughan, career coach and former tax director, to discuss how professionals can manage their critical inner voice and break down mental barriers in their mind.

With many years of experience working in tax at BP and PwC, Jo understands the high-achieving, perfectionist mindset that tax professionals often develop. In this episode, Alexis and Jo explore:

• the unique challenges professionals face in tax and other high-pressure jobs
• how the critical inner voice is amplified by competitive work environments
• practical tools for quieting self-doubt, including the FOG method (Fact, Opinion, Guess)
• the importance of getting out of your head and into your body through mindfulness and movement.

As discussed on the podcast, if you would like to sign-up for Jo’s mindful walks in London and Guildford this summer, you can do so here.

If you would like to discuss any of the matters raised in this episode, 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.

Hosted on Acast. See acast.com/privacy for more information.

In this episode of Taxing Matters, Senior Associate and Taxing Matters host, Alexis Armitage is joined by Thomas Slipanczewski, who is an Associate Director at Deloitte in their tax controversy team, to discuss task risk for regulated professionals and professional businesses in regulated sectors.

Facing a tax dispute or investigation can have a significant impact on an individual or business, and for those in regulated sectors such as lawyers, accountants and finance professionals, the associated reputational risks are often heightened. In this episode, Alexis and Thomas discuss:

• risks that regulated professionals and professional businesses should be aware of when they have a tax dispute or investigation;
• HMRC's perception of this taxpayer group and its implications; and
• 'top tips' for professional taxpayers facing a dispute or investigation.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

In our latest episode of RPC's Taxing Matters, podcast host and Senior Associate, Alexis Armitage, is joined by Mark Bevington managing principal and founder of ADE Tax.

With over 30 years' experience working in tax, Mark is a highly experienced strategic tax advisor, who has advised on numerous significant and complex transactions, disputes, negotiation support, policy and planning matters.

In this episode, Alexis and Mark explore the human side of tax disputes and discuss:

• the human elements of tax disputes and their potential impacts
• the difference between commercial disputes and tax disputes
• how complexities caused by the human side of tax disputes can be navigated
• the potential emotional impacts of tax disputes on individuals
• how mediation and ADR can help humanise the process
• advice and 'top tips' for tax professionals and taxpayers on handling the human side of disputes.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

This month, RPC Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Ele Theochari, Partner at Blick Rothenberg for a special episode to celebrate International Women's Day.

Ele is an R&D specialist who was promoted to Partner at just 29. Ele is passionate about helping companies to access R&D tax incentives and seeing the positive impact that R&D tax credits can have on a business. In this episode Alexis interviews Ele about:

• how she started her career in tax
• her journey to Partner and the challenges she's faced
• advice that previous mentors have given her
• role models she's looked up to throughout her career
• the charitable work she does alongside her day-to-day role.
• top tips for those starting their careers in tax.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

At the end of January, Mike Ashley won his high-profile and landmark data protection case against HMRC, with the High Court concluding that HMRC wrongly withheld his personal information for over two years.

In this month's episode of Taxing Matters, our host and Senior Associate, Alexis Armitage is joined by Megan Grew, Associate at RPC and part of Mike Ashley's legal team, to discuss the legal aspects of the case that led to a landmark data protection victory against HMRC for Mike Ashley in the High Court.

In this episode, they discuss:

• the background to the case and how it got to the High Court
• Mike Ashley's arguments v HMRC's arguments
• the court's judgment in the case, including in respect of costs
• practical implications of the win, and what this could mean for other individuals dealing with HMRC
• key takeaways from the judgment for HMRC and other government bodies.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. This episode discusses publicly available information only and does not disclose or imply any privileged or confidential details. RPC will not be providing further comments or media interviews on this matter. 

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In the latest episode of Taxing Matters, our host, Alexis Armitage is joined by Daisy Darrell, a Senior Associate in Birkett's Agricultural and Estates team to discuss all things natural capital.

Natural capital is the planet's natural wealth and the idea that the world has a stock of natural assets which provide ecosystem services like clean air, fertile soil and pollination of crops.

Join Alexis and Daisy as they explore:

• opportunities that natural capital can create for landowners
• examples of recent environmental enhancement and restoration projects
• the environmental benefits of such projects
• tax considerations for farmers and landowners
• potential impacts of ESG on natural capital markets

We hope you enjoy the episode. Please subscribe on Apple Podcasts or Spotify to keep up with future episodes.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

Hosted on Acast. See acast.com/privacy for more information.

In our special Christmas episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by Andrew Hubbard, editor-in-chief of Tolley's Taxation Magazine. From candles to beards, join them as they discuss the most bizarre taxes that have existed throughout British history.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

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In this month's episode of Taxing Matters, Alexis Armitage is joined by HMRC's Alternative Dispute Resolution (ADR) lead, Fiona McRobert, to discuss HMRC's approach to the ADR process, and how tax disputes may be resolved outside the Tax Tribunals and the court system.

During this episode they discuss:

• how the ADR process differs from formal litigation or an internal HMRC review
• the types of cases considered suitable for ADR (and those not suitable)
• the role of the mediator
• potential outcomes of the ADR process
• timelines and practicalities involved in the ADR process
• the pros and cons of ADR
• ADR success rates
• top tips.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

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In this episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and fellow Senior Associate, Jasprit Singh. Join them as they gaze into their crystal ball and predict what could be on the horizon for taxpayers under the new Labour government.

This episode covers:

• Labour's upcoming autumn budget
• HMRC's next potential targets and what they may focus on in the coming months
• the potential role of AI in HMRC's plans

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

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In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and Partner, Michelle Sloane, to discuss the latest issues surrounding the taxation of agents' fees in the football industry.

This episode covers:

• the financial relationship between players, their clubs and their agents
• HMRC's position on the tax split
• what clubs can do to evidence that the split reflects the commercial reality of the arrangement
• the high risk areas most likely to be investigated by HMRC.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

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In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

In this episode, we discuss:

• Spotlight 63 and HMRC's view of property business arrangements involving hybrid partnerships and why HMRC consider such arrangements to be fiscally ineffective
• the individuals and companies for whom Spotlight 63 might be relevant
• what the consequences might be for those who have participated in the type of property business arrangements referred to in Spotlight 63.

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