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Hargreaves Property Holdings Ltd v HRMC [2024] EWCA Civ 365 What are the practical implications of this case? The Court of Appeal’s handling of ‘beneficial entitlement’ signals that the judiciary will interrogate legal notions through the prism of the statute and, where fitting, adopt a purposive reading. For this taxpayer, however, beneficial entitlement was a settled legal concept that resisted a purposive gloss. As Lady Justice Falk made clear, no statutory notion enjoys immunity from purposive interpretation. The WHT regime is designed to secure collection where the payee of taxable income is outside the UK, and the disputed exemption recognises that those within the corporation tax net are not, for that reason, problematic. That rationale is not engaged on these facts. In addition, the Court of Appeal’s view of ‘yearly interest’ underlines an ongoing readiness to look past discrete steps and to focus on the commercial substance of the overall arrangement when testing how the tax code applies. Their analysis was anchored in statutory context rather than abstract doctrine,...
For alleged victims, a defendant’s apology can offer acknowledgement and emotional comfort, helping to lessen the personal strain of litigation. For the accused organisation, it is a fraught yet potentially reputation‑preserving step. The notion of apologising without accepting liability was introduced by the Compensation Act 2006 (ComA 2006). On 8 April 2024, the Ministry of Justice opened a consultation on legal reforms to make it easier for organisations to apologise. ComA 2006 was intended, in part, to confirm that an apology or an offer of treatment or remediation does not, by itself, amount to admitting liability. In principle, that safeguard should embolden organisations to apologise without fearing legal repercussions. In practice, however, the Act has not materially advanced this shift. The chief obstacle remains the public relations challenge that accompanies such statements. To the public, apologies are often read as acknowledgements of guilt, irrespective of the legal protections in place. That perception can strongly affect an organisation’s reputation and shape the conduct of proceedings, as stakeholders and wider audiences...
On 28 February 2025, the Central Bank of Ireland (Central Bank) issued an overview of recent changes to its supervisory model in its 'Our Approach to Supervision' publication. The Central Bank oversees a range of financial services sectors of differing scales, and developments in the industry since it launched PRISM, its risk-based supervisory framework, in 2011 have driven the need for a refreshed supervisory approach. The updated model will feature integrated supervision, with cross-disciplinary teams collaborating to deliver the Central Bank’s supervisory priorities more efficiently. These supervisory reforms are expected to materially affect firms over time. Safeguarding outcomes The Central Bank underscores the collective role of financial regulation, supervision (covering engagement, analysis and oversight of firms) and the implementation, monitoring and enforcement of regulations in delivering its four safeguarding outcomes: protection of consumer and investor interests the integrity of the financial system the safety and soundness of firms financial stability Changes to supervision The Central Bank’s evolving approach...