Relief Events meaning

In this issue: Arbitration in England & Wales International Arbitration Investment treaty arbitration Institutional and ad hoc arbitration Other arbitration and ADR-related news and developments Daily and weekly news alerts New and updated content Useful information No Weekly Highlights on 24 April 2025 Arbitration in England & Wales Arbitration clauses and third parties: limits of protection In Renaissance Securities v ILLC Chlodwig Enterprises [2025] EWCA Civ 369, the Court of Appeal refused an appeal for an anti-suit injunction (ASI) to halt Russian claims pursued against the appellant’s affiliates. Although parts of the dispute arose under contracts governed by English law with LCIA arbitration seated in London, the court concluded those promises to arbitrate did not bind non-party affiliates. It also dismissed the contention that the clauses carried an implied negative pledge preventing related litigation elsewhere. Moreover, while recognising the Russian action might be vexatious and/or aimed at sidestepping the arbitration provisions and relevant sanctions,...

FTT allows taxpayer’s R&D appeal (Stage One Creative Services Ltd v HMRC) In Stage One Creative Services Ltd v HMRC [2024] UKFTT 1059 (TC), the FTT upheld the company’s appeal concerning R&D claims. The business delivered engineering, construction and automation solutions for live events and installations. One project required it to design, build and install an intricate scenic set for a theatre production: an automated ‘pearl’ that flew across the auditorium and then opened to reveal a performer inside. The company sought R&D relief on costs incurred under multiple contracts, supported by detailed R&D reports. Typically, clients would approach with an idea and were more focused on the end result, not the methods adopted. The written agreements made no reference to R&D and were on a fixed-price basis, giving the company freedom to determine what research and development was necessary to achieve the brief. Knowledge arising from R&D and any intellectual property remained the property of...

In this issue: Private equity and venture capital 2025–26 — Fiscal events, including the Budget Taxes management and litigation Companies and corporation tax Employment taxes Individuals and income tax Share and asset sales VAT Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Private equity and venture capital Government issues response to consultation on tax treatment of carried interest Following its consultation on the taxation of carried interest—examining in particular the qualifying conditions for a new regime within the income tax framework and aiming to ensure the treatment most appropriately reflects economic reality—the Government has confirmed plans to introduce that regime from April 2026. The provisions will be set out in Finance Bill 2026, with draft legislation expected before the Parliamentary summer recess (normally mid to late July). Carried interest will be treated as trading profits and will fall within income tax and...

ARCHIVED This archived Practice note reviews the clawback of business investment relief (BIR), the remittance relief for investment into UK companies. It covers: extraction of value how to avoid a chargeable remittance after a potentially chargeable event the order in which disposals are treated the interaction with the mixed funds rules the capital gains tax (CGT) position STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime The Finance Act 2025 (FA 2025), which received Royal Assent on 20 March 2025, legislates to abolish the remittance basis of taxation and introduce a residence-based regime from 6 April 2025. FA 2025 also replaces domicile as the key criterion for inheritance tax liability. Additional changes include amendments to the excluded property rules, removal of protected settlements status for offshore trusts, and revisions to overseas workday relief. For details on these reforms, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based...

Business asset disposal relief Business asset disposal relief (BADR) is a capital gains tax (CGT) relief intended to encourage individuals to start and grow their own businesses. Where the qualifying conditions are met, for disposals made on or after 6 April 2026 the CGT rate on specified business assets is reduced to 18%. Before 6 April 2025 the rate available under BADR was 10%, rising to 14% from 6 April 2025 under the Finance Act 2025, which also provided for a further increase to 18% for disposals on or after 6 April 2026. Individuals operating as sole traders or in partnership Individuals disposing of shares in, or securities of, a company Trustees of a settlement holding the business assets Companies are not eligible for BADR in respect of chargeable gains that they realise. A lifetime cap limits the total amount of BADR that any one individual can claim...

This Practice Note outlines breach of contract and the remedies that may follow. It addresses what can constitute a breach, how the courts evaluate that question by construing the parties’ contractual obligations, the remedies available, and the deployment of clauses that cap or restrict consequent liability and/or compensation. It also looks at whether a breach of contract claim can be pursued and the method for claiming late payment interest. For a broader overview of contract law, see Practice Note: Ireland—Contract law essentials. Breach of contract A breach arises where one party (‘the defaulting party’) fails or declines to fulfil duties owed under the contract, in whole or in part. The other contracting party (‘the innocent party’) may then consider potential remedies for that failure. It should be remembered that a defaulting party with a lawful excuse for non-performance will generally not be in breach. This is distinct from force majeure clauses, which permit non-performance when specified events occur, eg war or sanctions, etc...

1 Definitions and interpretation In these Conditions, key terms include: Adequate Procedures (as per BA 2010); Affiliate (entities under common Control); Applicable Law (binding laws and guidance across relevant jurisdictions); Associated Person/Associated With (as defined for bribery, tax evasion and fraud by BA 2010, CFA 2017 and ECCTA 2023); Business Day (excluding weekends and bank/public holidays); Conditions (these sale terms); Confidential Information (commercial, technical or other identified confidential material); Contract (the agreement comprising these Conditions and the Order); Control (as specified); Customer and Supplier (the purchasing and supplying parties); Documentation; Force Majeure (events beyond reasonable control); Goods; Intellectual Property Rights and any IPR Claim; Location; MSA 2015; Order; Prevention Procedures; Price; Specification; VAT; and Warranty Period. Interpretation rules: references to the Contract include its schedules and annexes; headings are for convenience; references to a party include successors and permitted assigns; person includes natural and corporate bodies; company covers any body corporate; gender and number include each other; “including” and similar expressions are illustrative only; writing covers legible, non‑transitory...

What is inheritance tax? Inheritance tax (IHT) is, in general, a levy arising on an individual’s death, calculated by reference to the worth of that person’s net estate at the point just before death. The net estate is the aggregate worth of assets held by that individual, less the total of their borrowings and other obligations. To deter individuals from sidestepping the charge by making substantial transfers shortly prior to death, the regime also covers gifts made in the seven years preceding death. Certain further transfers and events that are not tied to an individual’s death may likewise be within the scope of IHT. When is IHT payable? ...

This Agreement is entered into on [ insert date ] (the Commencement Date) between the following: Parties [ insert supplier name ] a company incorporated in England and Wales, with registered number [ insert company number ], and with its registered office at [ insert registered office ] (the Supplier); and [ insert customer name ] a company incorporated in England and Wales, with registered number [ insert company number ], and with its registered office at [ insert registered office ] (the Customer), Each of the Supplier and the Customer is a party and, together, the Supplier and the Customer are the parties. Background (A) The Supplier’s background and the background to the relevant transaction are [ insert the Supplier’s background details and the background to the relevant transaction ]. (B) The Customer’s background is [ insert the Customer’s background details ]. (C) The Supplier intends to develop the Mobile App (as defined below), and the Customer...