Direct Participants meaning

Sarabande v HMRC [2025] UKFTT 93 (TC) SB, a registered charity, holds a long lease of a central London property (the Building). Suture Inc Ltd (SIL), SB’s wholly owned subsidiary, is not VAT-registered. In 2018, SB opted for voluntary VAT registration and sought to recover £341,487.31 of VAT incurred on purchasing and refurbishing the Building. The project transformed what had been a warehouse-style area into art studios, gallery space and meeting rooms. SB’s objective was to create a venue to nurture an artists’ community, and it devised a structured support scheme for artists called the ‘Accelerator Programme’. Through this programme, artists were offered curated, subsidised space, comprising studio and exhibition areas together with a bundle of benefits, including use of professional equipment, guidance from sector specialists and hands-on assistance from as well as advice from industry experts and practical support offered by SB within the Building to participants in the scheme on a structured basis throughout...

Background to OTSI guidance Following Russia’s assault on Ukraine in February 2022, the UK brought in trade sanctions covering a broad spectrum of goods, technology and services. Although direct commerce between the UK and Russia has fallen markedly since these measures were imposed, Russia has continued attempting to source such items indirectly, often via intricate supply chains. This trend has heightened the exposure of UK businesses to sanctions circumvention and the diversion of products to Russia. The methods used to sidestep restrictions are diverse and evolve rapidly, including fabricated end-use details, routed shipments, and the involvement of professional sanctions evasion networks. Participants across supply chains must recognise the diversion threats created by Russia’s procurement activity in this changed environment. Among other provisions, UK trade sanctions bar the export from the UK of sanctioned items to, or for use in, Russia, even where those items are first consigned to another destination. It is therefore vital for UK companies to identify the final destination of their products and to apply rigorous,...

In this issue: Key developments and materials Electricity and gas market regulation and licensing Networks and network connections Renewable energy Nuclear energy Planning issues in energy projects Air emissions, efficiency, and climate change International energy New and updated content Dates for your diary Energy resources on Lexis+® Daily and weekly news alerts Key developments and materials Ofgem consults on technical sandbox for testing AI in energy sector Ofgem is consulting on a proposed 12‑month pilot for an AI Technical Sandbox, creating a secure, supervised regulatory space where energy market participants can develop, trial and assess artificial intelligence (AI) solutions ahead of live roll‑out. The initiative is designed to nurture responsible innovation, protect consumers, uphold market integrity and energy security, and support progress towards net zero, while prioritising proportionate mitigation of direct harms and setting out how AI systems align with the existing energy regulatory framework. The consultation is open until 20...

FORTHCOMING CHANGE relating to UK transfer pricing: At Budget 2025, the government confirmed that it intends to move ahead with a new duty on in‑scope multinationals to submit annual information regarding cross‑border related party transactions and dealings for accounting periods starting on or after 1 January 2027. The detailed rules for the new ‘International Controlled Transactions Schedule’ (ICTS) are expected to be formally issued for technical consultation during spring 2026. A consultation on this measure ran from April through to July 2025. See News Analysis: Budget 2025—Tax analysis—International. This Practice Note reviews the UK transfer pricing rules as they apply to chargeable periods (referred to in this Practice Note for ease and convenience as ‘accounting periods’) commencing before 1 January 2026. Note that the Finance Act 2026 introduced a range of reforms to the UK’s transfer pricing regime, most of which apply for accounting periods beginning on or after 1 January 2026, subject to specified transitional provisions. For wider background on transfer pricing, see Practice Notes: Transfer pricing—what is...

This month has seen multiple merger control milestones: in Aruba, a new competition law featuring a merger control regime commenced; the Australian government published proposals to amend its merger regime; Belarus announced that revised thresholds will take effect on 7 July 2024; Egypt issued implementing regulations for its newly established pre-merger regime; and the UK adopted a new phase 2 merger review process. Aruba—new competition law enters into effect In Aruba, the Competition Regulation is now in force. It spans the three principal pillars of competition law, including merger control, and establishes a mandatory filing system. A deal must be notified where: the parties’ aggregate annual turnover is at least Afl 125m (approximately €64m/US$69.3m); and at least two parties each generate turnover of Afl 15m (approximately €7.7m/US$8.3m). There is also a duty to report where the participants hold a market share of 30% or more in one or more relevant markets in Aruba. At this stage, notifications are required for information-gathering...

What are property derivatives? Property derivatives are contracts where payments are linked to property prices used as the reference rate, determining what each party owes the other. They are available over the counter (OTC) or traded on exchanges. This remains a niche area for specialist investors, and usage in the UK has stayed limited. Why are property derivatives used? As with other financial derivatives, there is no single rationale for using them. They allow participants to gain exposure to movements in property values and can be used for speculation, hedging existing property positions, or transferring risk across portfolios. Such contracts provide a cost-effective route to express a view on property prices without the expense of direct investment. They are not typically subject to taxes such as stamp duty that would otherwise arise on direct property purchases. In line with other derivatives, they can also enable an investor to short the property market or a particular sector when they hold a negative outlook on future performance. Insurance companies,...

Please be aware that this precedent is provided solely for information purposes and constitutes a memorandum outlining the full particulars of the Model Code formerly included in the Listing Rules, which applied to directors of companies holding a premium listing of equity shares on the Financial Conduct Authority’s Official List. The FCA removed the Model Code as a direct consequence of the implementation of Regulation (EU) No 596/2014 on market abuse (the Market Abuse Regulation), which took effect on 3 July 2016. For further information on the Market Abuse Regulation, see Practice Notes: Market Abuse Regulation (MAR)—essentials [Archived] and UK Market Abuse Regulation—level 2 and level 3 measures. From 3 July 2016, The Chartered Governance Institute (formerly ICSA: The Governance Institute), GC100, the Quoted Companies Alliance (QCA) and other market participants issued a guidance note together with a range of specimen dealing codes for use by listed and quoted companies. For additional information on these materials, see Practice Note: ICSA, GC100, QCA: Market Abuse Regulation (MAR)...