When issued dealing meaning

HMRC may issue a revenue determination in relation to direct taxes when a taxpayer fails to submit a return in response to a notice requiring a return to be filed. Unless the determination was raised by HMRC in error, receiving one indicates a significant lapse in attending to tax affairs and compliance obligations. It should be addressed promptly as a matter of priority, and a taxpayer may wish to instruct an adviser to provide assistance. For detailed guidance on the consequences of a revenue determination for direct taxes and the options available to displace it, see Practice Note: What is a revenue determination for direct tax purposes? This Checklist sets out key practical considerations and the procedural steps to take once a taxpayer has been issued with a revenue determination by HMRC. Determinations concerning stamp duty land tax (SDLT) fall outside the scope of this Checklist. In contrast to revenue determinations relating to direct tax—where there is no right of appeal—there is a limited right of appeal against SDLT...

This checklist sets out a clear framework for dealing with a contractual debt claim at every stage: before issue on receipt of a letter of claim, and after issue on receipt of a claim form and particulars of claim. As a debtor facing a threatened or issued contractual debt claim, it can help to be aware of guidance directed at claimants (creditors), namely: Practice Note: Starting a contractual debt claim—a practical guide Starting a contractual debt claim—checklist Responding to a letter of claim Prior to starting court proceedings, the creditor ought to send a letter of claim that explains the debt and gives notice of the intended claim, whether the matter is governed by the Pre-Action Protocol for Debt Claims (the Protocol) or by the Practice Direction Pre-Action Conduct and Protocols (the Practice Direction). The table below identifies the key questions a debtor should ask when considering the letter of claim. If no letter of claim has been received and the...

LLC Eurochem North-West-2 and another company v Societe Generale S.A. and other companies [2025] EWHC 1938 (Comm) This is a highly important decision for practitioners dealing with international sanctions, as the court delivers a detailed examination of how EU sanctions interface with domestic sanctions authorities in such circumstances. It also provides an in-depth consideration of the notions of ‘ownership’ and ‘control’ for the purpose of sanctions, including where trust arrangements feature, which is not unusual when there is a link to a designated individual. The ruling is likewise of real assistance to those working with performance bonds and related trade finance instruments in the sanctions context. The background facts The relevant parties The dispute stemmed from six on-demand bonds (Bonds) issued in 2021 and 2022 by Société Générale (SocGen) and ING Bank (ING) (the Banks) in favour of EuroChem North-West-2 (EuroChem NW2), a Russian entity. The Bonds were issued under contracts between EuroChem NW2 and Tecnimont S.P.A (Tecnimont), an Italian engineering company, and its Russian affiliate...

In this issue: Regulated activities Prudential requirements Financial crime and sanctions Complaints, compensation and claims management Investigations, enforcement and discipline Regulation of derivatives Investment funds and asset management Consumer credit, mortgage and home finance FSMA regulated pensions activity Payment services and systems Dates for your diary New and updated content Financial Services Enforcement Database Daily and weekly news alerts LexTalk®Financial Services: a Lexis®Nexis community Regulated activities The Financial Conduct Authority has issued examples of strong and weak practice to help firms shape consumer segments for targeted support. These practical illustrations build on policy statement PS25/22, Supporting consumers’ pensions and investment decisions: rules for targeted support. Source: Targeted support: firm considerations when designing consumer segments... Prudential requirements The European Banking Authority has released its final draft amending regulatory technical standards on own funds and eligible liabilities, trimming the window for competent and resolution authorities to decide institutions’ applications...

In this issue: Data protection, cybersecurity and AI Financial sanctions LexTalk® Risk & Compliance: a Lexis®Nexis community Daily and weekly news alerts Trackers New and updated content Data protection, cybersecurity and AI ICO issues new guidance on secure document disclosure to reduce data breaches The Information Commissioner’s Office (ICO) has issued new guidance to support organisations in securely disclosing documents with significant volumes of information, especially when dealing with Freedom of Information (FOI) and subject access requests (SARs). It highlights the danger of unintentionally revealing concealed personal data—such as metadata, hidden rows, columns, worksheets and active filters—and provides practical actions, checklists and how-to videos to help organisations detect and remove this material. The advice also suggests converting files into simpler formats, steering clear of ineffective redaction approaches, and employing tools such as Microsoft Document Inspector. See: LNB News 05/08/2025 38...

STOP PRESS: On 19 June 2025, the Data (Use and Access) Bill secured Royal Assent, transforming into the Data (Use and Access) Act 2025 (DUAA 2025) and taking partial effect on that same date. Provisions of DUAA 2025 dealing with issues such as handling data subject access requests, and granting the power to make further regulations, commenced immediately on 19 June 2025. Other elements, relating to notices issued by the Information Commissioner and certain facets of law enforcement processing, began to apply on 19 August 2025 (being two months from the date of Royal Assent). The bulk of DUAA 2025’s measures will only commence once additional regulations, by way of statutory instruments, are made and brought into force. Parts 5 and 6 of DUAA 2025 operate to revise and update areas of UK data protection and ePrivacy law within the UK, including the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations...

This Practice Note sets out the applicable product governance obligations under the Markets in Financial Instruments Directive (Directive 2014/65/EU) (MiFID II) that firms must observe and comply with when designing, approving, marketing and overseeing the ongoing management of products throughout their entire lifecycle. It also summarises the relevant delegated acts adopted by the European Commission—particularly Articles 9 and 10 of Directive (EU) 2017/593 (the MiFID II Delegated Directive)—as well as the guidelines issued by the European Securities and Markets Authority (ESMA). Background to MiFID II and product governance The recast Markets in Financial Instruments Directive (Directive 2014/65/EU) (MiFID II), together with the Markets in Financial Instruments Regulation (Regulation (EU) 600/2014) (MiFIR) (collectively, the MiFID II framework), entered into force on 2 July 2014. The bulk of the framework’s provisions largely applied from 3 January 2018. MiFID II establishes a suite of product governance requirements so that firms manufacture and distribute products in a manner that ensures they act in clients’ best interests across every stage of the lifecycle...

For an at‑a‑glance, high‑level outline of the civil court structure and hierarchy in England and Wales, see: Courts and Tribunals Judiciary—Structure of Courts and Tribunals System. Several civil courts issue a court guide explaining how business in that court should be managed, which operates alongside, and in addition to, further guidance given in the Civil Procedure Rules (CPR). For further details, see Practice Note: Court guides and other guidance. For information on: claims that must be brought and issued in the County Court, see Practice Note: Starting civil claims in the County Court commencing a claim under CPR 8 (alternative procedure for claims where there is no substantial dispute of fact), see Practice Note: CPR Part 8 claims (alternative procedure for claims) High Court or the County Court? Whether proceedings ought to be issued in the High Court or the County Court is, in the main, determined by the claim’s value. This Practice Note addresses starting a claim under CPR 7. The...

We proceed on the basis that the company is UK-resident and that the dividend is not being made between companies within the same group for tax purposes. When analysing the tax consequences for the distributing company, the initial enquiry is to determine whether the transaction sits within the statutory rules on loan relationships or, alternatively, within the corporation tax provisions dealing with chargeable gains. In the ordinary course, a loan note held by a company is regarded, for tax purposes, as a loan relationship, and is treated in line with that classification...