Taxing Matters

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.

Update – August 2026: This episode was recorded in 2024 and principally concerns HMRC’s Spotlight 63 and property-business arrangements involving hybrid partnerships. During the discussion, the external guests also commented upon Property118 Limited’s Substantial Incorporation Structures (SIS) and Capital Account Restructure (CAR) arrangements. The opinions expressed by the external guests in this episode reflected their personal views as at the date of the recording.

On 31 July 2026, the First-tier Tribunal allowed appeals brought by Property118 Limited and Cotswold Barristers Limited, against HMRC’s allocation of Scheme Reference Numbers under the Disclosure of Tax Avoidance Schemes (DOTAS) regime. The decision addressed only whether the SIS and CAR arrangements were legally notifiable under the DOTAS rules.

The First-tier Tribunal's decision can be accessed here: https://caselaw.nationalarchives.gov.uk/ukftt/tc/2026/1111

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In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

In this special episode for Fair Tax Week, Alexis and Paul discuss:

• the Fair Tax Foundation and its aims
• tax transparency and good governance
• how organisations can become Fair Tax Mark accredited
• the requirements for accreditation
• key performance indicators.

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 this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".

This episode considers the loan charge controversy, including:

• The background to the introduction of the charge.
• Those primarily impacted by the charge.
• Why it remains relevant today for so many taxpayers.
• What can be done to resolve the loan charge saga once and for all.

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 this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.

This episode covers the major changes to the UK's non-domicile regime proposed by the Government, including:

• The shift from domiciled-based taxation of individuals to the new residence basis for taxation of individuals.
• Transitional reliefs for current non-domiciled individuals.
• The inheritance tax implications of switching from a domicile basis to a residence basis. 

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.

To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.

RPC's Taxing Matters host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage is joined by three inspirational female leaders working in tax:

•  Tasneem Kadiri, Tax Director for UK & Ireland at L’Oréal.

•  Dipti Thakrar, M&A Tax Practice Lead at Hitachi Energy.

• Ashling Donnelly, Head of Tax at Trainline.

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In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

Patrick is one of the founders of Field Court Tax Chambers. He has successfully represented clients at all levels of the UK court system and has acted for both taxpayers and HMRC.

In this episode, the following will be discussed:

• How HMRC treat payments when musicians sell their rights in respect of recordings and publishing rights

• How the worldwide sponsorship income and other worldwide income of musicians and sportspersons are taxed in the UK when they play at concerts or appear at sporting events in the UK

• IR35 – an update on where we are after the Kaye Adams / Atholl House case

• The latest position of HMRC in relation to image rights contracts; and a brief discussion on the taxation of agents' fees (a further podcast will follow from our very own Michelle Sloane on this topic in April – watch this space!).

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In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.

We are delighted to be joined by our very own expert Olivia Dhein. Olivia is a Knowledge Lawyer at RPC. Prior to joining RPC Olivia was a Professional Support Lawyer at Lexis Nexis and before that she was a commercial disputes lawyer at Freshfields. Olivia is an expert in this dynamic and rapidly changing area.  

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As the cost of living crisis bites more than ever this year, in this special Christmas episode of RPC's Taxing Matters, we bring you some Christmas cheer by way of a light-hearted discussion of some of the potential ways you may be able to reduce your tax bill. In addition, we'll also have a quick look at Santa's tax position in the run up to Christmas and whether he might be guilty of tax avoidance … or even tax evasion!

We are delighted to be joined by guest speaker Sam Brodsky. Sam is a barrister at Gray's Inn Tax Chambers and has a busy practice covering the full range of UK tax, commercial and chancery law. He is regularly instructed in the High Court and the Tax Tribunals both as lead and a specialist tax and/or property junior and most importantly, he has a great sense of humour. 

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