Taxing Matters

Taxing Matters: Whistleblowing under the Strengthened Reward Scheme, with Adam Craggs

In this episode of Taxing Matters, host Michelle Sloane is joined by RPC's Head of Tax, Investigations and Financial Crime, Adam Craggs to examine the merits and drawbacks of the Strengthened Reward Scheme (SRS).

Launched by HMRC in November 2025, the SRS represents a significant change in HMRC's approach to tackling serious tax avoidance and evasion, with a powerful new incentive for whistleblowers.

This episode explores:

• the background to the SRS, and what it means for the UK whistleblowing landscape;
• what makes a strong disclosure, and the types of 'big ticket' cases that will attract HMRC's attention;
• guidance and considerations for potential whistle blowers;
• anonymity and the need for self-identification;
• practical implications, including tax considerations and when a reward may not be paid; and
• key takeaways for businesses and advisors.

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 Michelle Sloane.

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 RPC’s Taxing Matters podcast, host Michelle Sloane is joined by Clive Brady to look at vaping duty, a new excise duty now on the statute books.

Drawing on Clive's extensive experience advising on excise duties, the episode explores:

• an overview of the new vaping products duty, including what and what isn't in scope;
• the key dates and implementation timetable;
• who the regime captures across the supply chain;
• how duty is charged and administered in practice; and
• the compliance and enforcement risk areas your business needs to be aware of.

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 Michelle Sloane.

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 RPC’s Taxing Matters podcast, Michelle Sloane, Partner in our Tax, Investigations and Financial Crime team, is joined by Joshua Carey of Devereux Chambers to explore HMRC’s increasingly robust approach to supply chain fraud, and what this means in practice for businesses.

Drawing on their extensive experience in complex tax and public law disputes, Michelle and Joshua discuss:

• how supply chain fraud can arise and how businesses can find themselves implicated, sometimes unwittingly, in these chains
• HMRC’s investigative toolkit and the legal framework it relies on, including the “knew or should have known” test
• the growing use of penalty provisions that can affect both corporate entities and individuals
• the potential civil, criminal and reputational consequences of being caught up in a fraudulent supply chain
• what businesses can do to help protect themselves.

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 Michelle Sloane.

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 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.

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

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.

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

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.

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 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.

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.

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.