R (Greyhound Board of Great Britain Ltd) v Welsh Ministers [2026] EWHC 670 (Admin) What are the practical implications of this case? The ruling reinforces the constitutional divide between the courts and the legislature. It explains that the scheme and framework of the Government of Wales Act 2006 (GWA 2006) embody that separation of powers, and that any judicial attempt to recognise and enforce a common law obligation on Welsh Ministers to consult prior to introducing legislation in the Senedd would trespass upon that boundary. This is not a departure from established principle; case law has already upheld comparable rules for lawmakers in Scotland and at Westminster. However, this is the first express confirmation of the position for Welsh lawmakers, and the first time this dimension of the GWA 2006 has been analysed in such depth. The court examined earlier
The solution arrived through the United Nations Compensation Commission (UNCC), a quasi‑judicial body handling mass claims, created under UN Security Council Resolution 687. By addressing environmental harm—most notably via its ‘F4’ claim class—the UNCC set a seminal benchmark shaping how international law and contemporary arbitral panels allocate financial responsibility for wartime ecological devastation. With present-day wars in areas such as Eastern Europe and the Middle East bringing dam breaches, strikes on chemical facilities, and the burning of farmland, the UNCC’s legacy endures as an essential reference point for states, global investors, and companies engaged in post‑conflict arbitration. The F4 claims: Quantifying the unquantifiable Prior to the 1990s, mechanisms in international law for war reparations overwhelmingly favoured property loss, foregone earnings, and bodily injury. The natural world was commonly treated as a mute, non-compensable victim of armed hostilities...
Understanding the farming business as a business Many farms still use long-standing structures that arose by habit, not strategy. Sole traders, informal partnerships and outdated partnership deeds are common. While once effective, such setups can cause major issues around succession, tax planning and involving the next generation. A corporate team can take a fresh, business-led view of the farm, asking: Who owns the land and other critical assets? Who manages daily operations? Who carries the risk and who enjoys the return? What is the enduring plan for succession? From this review, the team can confirm whether the current setup is fit for purpose or if an alternative — for example an updated partnership agreement, a company, a limited liability partnership, or a blended model — would better meet the family’s aims. Tax efficiency through joined-up advice Tax sits at the centre of most
In this issue: Tax treatment Corporate governance Q& As Weekly highlights from other practice areas Tax treatment Janet Bray Ltd v HMRC The First-tier Tax Tribunal ( FTT) rejected the taxpayer’s appeal against determinations for PAYE and penalties arising from a tax planning arrangement using an employee benefit trust. Both parties accepted that the arrangement failed to deliver the expected tax advantages, and the central question was whether carelessness had caused a loss of tax sufficient to engage the extended six‑year window for assessment. The FTT initially concluded that the company had not exercised reasonable care. While three separate groups of tax specialists participated in putting the arrangement in place (the company’s accountants, their network organisation, and the scheme’s promoters), the FTT found that none had been retained by the company to give it tax advice on the arrangement, and that each professional had expressly stated they were not doing so. The...
In this issue: Corporate governance Q& As Useful information Weekly highlights from other practice areas Corporate governance Quoted Companies Alliance publishes report on proxy advisers Following its survey of small and mid-cap companies (see: Share Incentives weekly highlights—25 July 2024), the Quoted Companies Alliance ( QCA) has issued a report setting out the survey results, spotlighting difficulties companies encounter with the remit and conduct of proxy advisers and suggesting remedies. Firms pointed to tick-box, one-size-fits-all governance assessments and limited appreciation of individual circumstances. On pay, the report highlights uneven treatment across markets: the same adviser may urge votes against a UK-quoted company’s policy yet back US and European peers that routinely table higher remuneration, creating headaches for globally active businesses. The report further records worries that proxy adviser recommendations frequently overlook each company’s distinct profile, and that weak...
In this issue: Tax treatment Q& As Weekly highlights from other practice areas Tax treatment Minor updates to HMRC factsheets on employee tax-advantaged share scheme penalties HMRC has made modest revisions to its factsheets on penalties that can arise where a scheme does not satisfy the conditions for tax-advantaged status, and where an annual share schemes return for a tax-advantaged scheme filed with HMRC includes a material inaccuracy. The updated materials now also provide extra detail on support available during compliance checks, rights relating to penalties, and the subsequent steps if there is disagreement with an HMRC decision. For further detail on these penalties and the procedures for each type of tax-advantaged employee share scheme, see Practice Notes: Self-certification, registration and filing requirements for SIPs and SAYE schemes; HMRC annual return filing requirements for SIPs and SAYE schemes; CSOP—self...
In this issue: Corporate governance Q& As Useful information Weekly highlights from other practice areas Corporate governance ASOS Plc shareholders approve new value creation plan At ASOS Plc’s general meeting this week, investors endorsed both its contentious new value creation plan ( VCP) and a revised remuneration policy, with more than 91% of votes cast in favour of each resolution. The VCP is intended to align executive directors and the senior leadership team with the company’s ‘ambitious growth plans’, motivating management ‘to deliver exceptional returns’ for shareholders. Under the VCP, participants will be granted nil-cost options, giving a right to share in a value pool equal to 5.5% of the company’s growth in value above £6.70 per share (around twice the share price when the VCP design work began). Executive directors’ awards will vest in two equal tranches after four and five years...
Corporate governance Barclays and Citigroup to lift bankers’ bonus cap Reports indicate Barclays plc will be the first UK lender to remove the bonus ceiling for its material risk takers, after shareholders at its May 2024 AGM authorised the board to set whatever fixed-to-variable pay ratios it deems suitable (see: Share Incentives weekly highlights-9 May 2024). The previous cap stemmed from EU-derived rules applying to UK staff, which the FCA and PRA abolished with effect from 31 October 2023 via their joint policy statement PS9/23- Remuneration: Ratio between fixed and variable components of total remuneration (bonus cap)-see: Share Incentives weekly highlights-26 October 2023- Company law, governance and regulatory issues. Mirroring JPMorgan’s stance, Barclays is expected to hold base salaries for material risk takers steady while permitting variable awards up to ten times fixed pay, replacing the prior two-times ceiling. There are also reports that...
In this issue: SAYE schemes Corporate governance Useful information Weekly highlights from other practice areas SAYE schemes Change in bonus rates for SAYE schemes HMRC has set revised bonus rates and an updated early leaver rate for save as you earn ( SAYE) arrangements, to be applied to fresh invitations issued from 16 August 2024. This follows last year’s introduction of an automatic SAYE bonus rate mechanism, calculated by reference to the Bank of England base rate (see: Share Incentives weekly highlights—1 June 2023— SAYE Schemes). In light of last week’s change to the base rate, HMRC has confirmed the following SAYE figures: three-year SAYE savings contract bonus: 1.1 times one monthly contribution five-year SAYE savings contract bonus: 3.0 times one monthly contribution early leaver rate: 1.33% These rates take effect from 16 August 2024, and employees already saving under...
In this issue Tax treatment Regulatory Budgets, Autumn Statements and Finance Bills Useful information Weekly highlights from other practice areas Tax treatment HMRC publishes Employment Related Securities Bulletin 56 HMRC has issued Employment Related Securities Bulletin 56, outlining guidance on tax and reporting duties for dividend income and for share sales and disposals within employee share schemes. On dividend income, it notes: There is no need to report dividends that fall within the £500 dividend allowance, and dividends from shares held in ISAs are always tax-free. Where taxable dividends are £10,000 or less, liability can be settled via a tax code adjustment or by completing a Self Assessment return. If dividends exceed £10,000, filing a Self Assessment return is mandatory. Dividends from non- UK companies may have had withholding tax deducted abroad, which can be...
The consultation on the draft legislation runs until 15 September 2024. FB 2025 is anticipated to be brought before Parliament after the Autumn Budget and is therefore expected to obtain Royal Assent in spring 2025. The complete set of measures for FB 2025 is available here, and the written ministerial statement by James Murray, Exchequer Secretary to the Treasury, summarising these measures is here. Draft legislation Three draft FB 2025 provisions have been issued, one of which is the Pillar Two anti-arbitrage rule designed to counter arrangements that exploit differences between tax and accounting rules, first announced in a written ministerial statement on 14 March 2024. For further details on that publication, see below. the abolition of the furnished holiday lettings regime, as announced at Spring Budget 2024 (see News Analysis: Spring Budget 2024— Tax analysis— Real estate taxes), and the removal of the VAT...
For the principal business tax measures, see News Analysis: Legislation Day: Draft Finance Bill 2025— Tax analysis. Also see: 2024: Non- UK domiciled individuals—policy summary Collection: Finance Bill 2024–25 — draft legislation and technical tax documents Initial reactions from the market Jeremy Woolf, Pump Court Tax Chambers: The most notable document among the technical tax papers issued on 29 July for Private Client practitioners is the one concerning the non-domiciled. It broadly reflects the last Budget’s proposals. It outlines a regime under which new residents would not be charged for four years on overseas income and gains, describing it as ‘internationally competitive’ and aimed at attracting top talent and investment to the UK. I worry that jurisdictions offering longer relief periods may appear more appealing. The paper also confirms the government’s rejection of the earlier idea of a specific transitional relief that would have given those who...
In this issue: Corporate governance Useful information Weekly highlights from other practice areas Corporate governance FRC announces updates to the UK Stewardship Code The Financial Reporting Council ( FRC) has outlined changes to the application route for the UK Stewardship Code (the Code) and highlighted five key areas for scrutiny as it progresses with the wider refresh of the Code, first trailed in February 2024 (see: Share Incentives weekly highlights—29 February 2024). The Code sets out 12 ‘apply and explain’ Principles for asset managers and asset owners, alongside a distinct suite of six Principles for service providers, such as proxy advisers......
In this issue: Budgets, Autumn Statements and Finance Bills Corporate Governance Remuneration issues for financial services firms Useful information Weekly highlights from other practice areas Budgets, Autumn Statements and Finance Bills King’s Speech 2024 At the State Opening of Parliament held on 17 July 2024, His Majesty King Charles III set out the government’s priorities and proposed policies for the forthcoming parliamentary session. This includes 40 legislative proposals to be addressed during the 2024–25 parliamentary session. Although no measures directly relating to share incentives were put forward, the announcements of greatest relevance included: a Draft Audit Reform and Corporate Governance Bill with the purpose of ‘strengthening’ corporate governance......
In this issue: Company law, governance and regulatory matters Corporate Governance Useful information HMRC Manuals tracker Weekly highlights from other practice areas Company law, governance and regulatory matters FCA overhauls UK Listing Rules Following its consultation paper CP23/31 issued on 20 December 2023, the Financial Conduct Authority ( FCA) has unveiled a new UK Listing Rules sourcebook that will supersede the current Listing Rules and take effect from 29 July 2024. The FCA says these measures, marking the most substantial reshaping of the listings regime in more than three decades, introduce a simplified structure with a single category and streamlined eligibility for companies seeking to issue their shares in the UK. By reducing complexity, the changes aim to support a broader spectrum of companies to come to market on a UK exchange and to widen...
In this issue: Tax treatment Corporate Governance Useful information Weekly highlights from other practice areas Tax treatment HMRC publishes employee share schemes statistics for the tax year ending 2023 HMRC has released statistics for the tax year ending 2023 covering the tax-advantaged employee share schemes, namely company share option plans ( CSOPs), enterprise management incentives ( EMI), save as you earn ( SAYE) and share incentive plans ( SIPs). Drawn from share scheme returns, the figures outline how many companies operate these schemes, how many employees received awards and the overall number of awards, the values granted, the numbers of employees who exercised options, and estimates of the amount of income tax and national insurance contributions ( NICs) relief obtained......
In this issue: Corporate Governance Useful information HMRC Manuals tracker Weekly highlights from other practice areas Corporate Governance More controversial pay plans at Wizz Air Wizz Air Holdings Plc has outlined a revised approach to long term incentive plan ( LTIP) awards for senior managers below the CEO, a move likely to stir debate at its AGM later this summer. In the prior year, LTIPs were split evenly between performance shares and time‑vested restricted shares. For the 2025 financial year, however, the remuneration committee has opted for a one‑off change so the entire LTIP will be made up of time‑vested restricted shares vesting over three years. The potential maximum under the LTIP remains at 250% of base salary, rising to 300% in exceptional cases. While remuneration committee chair Barry Eccleston concedes the structure is atypical, the annual report contends it is...
Cox and another v HMRC [2024] UKFTT 510 ( TC) A married couple, the taxpayers served as directors and minority shareholders in a company that operated as financial advisers. Each owned roughly 6% of the share capital. In 2018, several shareholders, including the couple, chose to sell their shares to other continuing shareholders. During a meeting between the directors and a representative of the solicitors dealing with the sale, EWM, the representative went round the table to confirm that every director and their spouses would be entitled to entrepreneurs’ relief on the disposal. Afterwards, the directors determined that the sale consideration should be divided so as to better reflect each person’s contribution to the business. Consequently, the taxpayers each gifted part of their shareholding to other shareholders. Those gifts qualified for holdover relief but left each taxpayer with a 4% stake in the...
In this issue: Tax treatment Corporate Governance Useful information Weekly highlights from other practice areas Tax treatment Reminder— Annual share schemes returns filing deadline is 6 July 2024 If a company runs any tax-advantaged or non-tax-advantaged employee share scheme through which UK participants receive shares or share-based awards, an online annual return must be filed with HMRC for that scheme. The deadline to submit annual share scheme returns for the 2023–24 tax year is 6 July 2024, and the scheme must already be registered with HMRC before a return can be lodged. HMRC has published templates, guidance and technical notes setting out the information that must be included in the annual return. As each scheme type has its own template, care should be taken to use the correct version. Even where a registered scheme has no reportable events in the relevant tax year, a nil...
The Liberal Democrats said they would indeed almost double capital gains tax for the highest earners if they managed to form a majority government after the 4 July general election. Capital gains is a levy on the profit made when an asset is sold. At present, the top rate is currently 24%. The Lib Dems intend to increase it to 45% under their plans. Ed Davey, the party’s leader, told a press conference unveiling the manifesto that it is only right the very, very wealthiest in our country pay more tax, insisting that when our public services are right now crying out for......
At the Manchester manifesto launch, the Labour leader pledged his administration would set up a National Wealth Fund capitalised at £7.3bn ( US$9.3bn) across the next Parliament. Its purpose is to speed the shift to clean energy and support industry while drawing in private co‑investment alongside public funds. The fund’s remit would be clean power and industrial investment, targeting £3 of private capital for each £1 of state funding. A Labour administration would likewise undertake a wide-ranging review of pensions, including measures to lift workplace scheme investment into domestic markets. “ This is a changed Labour Party with a plan for growth,” Starmer told delegates. “ We are pro‑business and pro‑worker — the party of wealth creation.” He added that his party, polling 20 points ahead of the governing Conservative Party, reaffirmed prior commitments not to raise income tax, National Insurance or VAT if...
At Silverstone, the Midlands Grand Prix circuit, the Prime Minister unveiled his party’s general election manifesto, promising to cut employees’ National Insurance contributions, taken from wages, to 6% by April 2027—provided the Conservatives overturn their roughly 20-point polling gap. The Conservative administration has already reduced the rate in two stages, from 12% in November to 8% in March. The 80-page manifesto also outlines an ambition to scrap the levy altogether over time. Sunak restated his party’s adherence to the pensions triple lock, ensuring the state pension rises each year by average earnings, inflation, or 2.5%, whichever is higher. He also reiterated a May pledge that state pension payments would always remain below the income tax threshold, as part of a plan......
In this issue: Corporate Governance General Election 2024 Weekly highlights from other practice areas Corporate Governance FRC chief expresses concern at the role of proxy advisers in executive pay Richard Moriarty, head of the Financial Reporting Council ( FRC), is said this week to have urged boards to resist proxy advisers seeking to block increases in executive pay. He also signalled that the FRC is reviewing the influence of proxy advisers and considering tougher supervision. He raised doubts about whether expectations of proxies in the UK Stewardship Code should be revisited; the Code is being consulted on by the FRC, with an updated draft anticipated next year (see: Share Incentives weekly highlights—29 February 2024— Corporate governance). His remarks come amid repeated assertions from business leaders in recent months that more generous executive awards would bolster UK competitiveness and help British firms attract global talent with less friction (see: Share...
When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...
This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...