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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 Sole traders, informal partnerships and outdated partnership deeds are common.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
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In this issue: Corporate governance Regulatory HMRC Manuals tracker Useful Information Weekly highlights from other practice areas Corporate governance FRC publishes guidance supporting the UK Corporate Governance Code 2024 The Financial Reporting Council ( FRC) has released refreshed guidance to assist companies with applying the UK Corporate Governance Code 2024 (issued last week—see: Share Incentives weekly highlights—25 January 2024— Corporate governance). Although it is not an integral component of the Code, the guidance is designed to help organisations interpret the updated provisions by offering additional advice, depth and illustrations. Instead of prescribing compulsory actions, it seeks to promote constructive dialogue and collective decision-making so that companies can embed the Code’s principles effectively. The guidance is structured to reflect the Code’s own layout, covering: section 1—board leadership and company purpose section 2—division of...
In this issue: Corporate governance Retained EU law Q& As Useful Information Weekly highlights from other practice areas Corporate governance FRC revises UK Corporate Governance Code The Financial Reporting Council ( FRC) has published an updated UK Corporate Governance Code ( UKCG Code) (the 2024 UKCG Code), introducing only modest amendments to the 2018 iteration (the 2018 UKCG Code). This update follows the FRC’s consultation issued on 24 May 2023, which backed the legislative changes set out in the government’s response to its May 2022 White Paper, Restoring Trust in Audit and Corporate Governance (for further details, see: Share Incentives weekly highlights—25 May 2023— Corporate governance). The consultation presented 18 proposals to revise the 2018 UKCG Code, with an emphasis on establishing a stronger framework for prudent, effective risk management and internal controls. However, on 7 November 2023 the FRC stated that it...
To watch the video of their discussion, simply click here. A written summary of the issues examined, with onward links to our related materials, appears below. Why has the issue of whether annual bonuses should be taken into account when calculating holiday pay become a hot topic? Employers have typically (rightly or wrongly) left annual bonuses out when working out a worker’s holiday pay. Concern has arisen that the amended wording brought into the Working Time Regulations 1998 ( WTR 1998), SI 1998/1833, from 1 January 2024, requires at least some annual bonuses to be factored into holiday pay in certain cases. What is an annual bonus? The reply may appear straightforward: it is a bonus paid once each year. Yet bonuses differ in nature, and that distinction could ultimately affect how we respond to the question of whether they ought to be included when...
In this issue: Mandatory payroll reporting on benefits of kind to apply from April 2026 HMRC Manuals tracker Useful Information Weekly highlights from other practice areas Mandatory payroll reporting on benefits of kind to apply from April 2026 This week, the government unveiled a package of measures intended to streamline and modernise the tax system. Included is confirmation that, from April 2026, employers will be required to use payroll software to report and pay income tax and class 1A national insurance contributions on benefits in kind. HMRC has indicated it will engage with stakeholders to consider proposals that shape design and delivery decisions, with draft legislation to be issued later in the year as part of the tax legislation process. HMRC will also partner with industry specialists to develop guidance, which will be available ahead of 2026. Further details will be communicated through the usual channels, such as...
In this issue: Budgets, Autumn Statements and Finance Bills Tax treatment Corporate governance Useful Information HMRC Manuals tracker Weekly highlights from other practice areas Budgets, Autumn Statements and Finance Bills Spring Budget date confirmed HM Treasury has announced that the Spring Budget 2024 is set for 6 March. See Spring Budget 2024 date confirmed. 27 December 2023 Tax treatment HMRC reminds companies to save copies of ERS returns and notifications HMRC has introduced a minor update to its published guidance on submitting and filing employment related securities ( ERS) returns and notifications, to stress that companies should retain a copy of everything submitted for their own records, because the online service does not preserve the details and it will not be possible to retrieve the filing later. For more detailed information on the requirements and process, see Practice Note: FAQs on UK share...
What are the practical implications of this case? In Commissioners for His Majesty’s Revenue and Customs v Vermilion Holdings Ltd [2023] UKSC 37, the ruling carries notable, practical consequences for employers aiming to grant shares or share options to company officers or employees. Unless an officer or employee can rely on one of the exceptions in ITEPA 2003, s 471(3), any option issued while they hold office or employment will be classified as an employment-related security and, accordingly, taxed as employment-related income. The purpose behind offering the security option to the relevant officer or employee is immaterial. There is, however, an open question as to whether ITEPA 2003, s 471(3) will remain the central provision where options are granted to former employees or individuals yet to begin employment with the company. It appears, on balance, more likely that in those...
HMRC v Vermilion Holdings Ltd [2023] UKSC 37 Background This appeal revolved around the construction of ITEPA 2003, s 471. That provision identifies when an option to obtain securities (including company shares) is given ‘by reason of employment’ and so chargeable to income tax rather than capital gains tax. In 2006, Vermilion Holdings Ltd ( Vermilion) granted Quest Advantage Ltd ( Quest) an option to acquire shares in Vermilion (the 2006 Option). By late 2006, Vermilion’s performance had deteriorated. As part of a rescue funding arrangement, Vermilion and Quest agreed to vary the 2006 Option. In July 2007, they executed a fresh option agreement (the 2007 Option), under which Quest subscribed for a new class of Vermilion shares and the 2006 Option lapsed. In 2016, Quest assigned the 2007 Option to Mr Noble. Quest sought HMRC’s confirmation that the assignment fell within capital gains tax. HMRC...
What changes to entrepreneurs’ relief were announced at the Budget 2018 and what was the motivation behind them? What is their likely impact? There will be three amendments to entrepreneurs’ relief in the Finance Act 2019. Diluted holdings The first reform permits a shareholder whose interest falls below the 5% qualifying threshold to elect to be treated as having disposed of, and immediately reacquired, their shares just before the dilution, effectively banking entrepreneurs’ relief for the qualifying holding period. The driver for this was a perceived obstacle to third-party investment in entrepreneurial businesses, where fundraising could push existing owners under the 5% line. In practice, the arrangement demands two distinct elections: one to crystallise the deemed sale and repurchase, and a separate one—on different deadlines—to defer the liability until an actual disposal, unless the person prefers to pay the capital gains tax upfront as a ‘dirty’ tax charge....
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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 ]...
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