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The new securitisation rules In this briefing, Kate Patane outlines the key take-aways from the two recent policy statements issued by the PRA and FCA on the UK Securitisation Regulations. On 30 April 2024, both the Financial Conduct Authority (FCA) and the Prudential Regulation Aut... Hargreaves in the Court of Appeal: A return to orthodoxy on withholding taxes? The Court of Appeal has dismissed Hargreaves’ appeal against the Upper Tribunal’s decision and determined that tax should have been withheld from interest paid on loans advanced to the group. The judgment provides taxpayers and their advisers ... BLOG: VAT recovery on shares sale: no special rule for fundraising transactions The UK Court of Appeal’s decision in Hotel La Tour has dashed taxpayers’ hopes of being more readily able to recover VAT paid on deal fees in respect of share sales. It is possible that the taxpayer may seek to appeal to the Supreme Court (after all, the ... Last but not least: consultation involvement key to avoiding regulatory divergence in public and private securitisations In this In Practice article Kate Patane considers the growing divergence between EU and UK reporting obligations in public and private securitisations and how detailed feedback can drive internal “change management” processes and encourage the... BLOG: Tax Disputes Podcast: France I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to Paris for a stimulating conversation between myself, my colleague, tax partner Charles Osborne and Julien Gayral, tax pa... Drafting for extension options - The LMA extends a hand In this briefing, Matthew Tobin, Ed Fife, Kathrine Meloni and Latifah Mohamed provide an overview of the LMA’s new drafting for extension options and consider a few key points for borrowers to keep in mind when looking to incorporate an extension op... BLOG: Challenging dawn raids in the UK HMRC raided the London offices of a global financial brokerage business and the home of a former employee on 28 September 2022, following requests for assistance from Germany and Denmark for criminal investigations in respect of cum-ex trades. The busines... Competition & Regulatory Newsletter: European Commission designates Booking as a gatekeeper under DMA and opens market investigation into X On 13 May 2024, the European Commission announced that it has designated Booking as a gatekeeper under the Digital Markets Act, for its online intermediation service Booking.com. The Commission has also opened a market investigation to assess whether X sh... BLOG: Tax Disputes Podcast – Nigeria Our “trip” through tax disputes landscapes around the world is sadly nearing its end (and by “trip”, I mean a six-part podcast series on tax disputes in G20 countries across six continents). This stop in Nigeria marks the penultimate episode in the series... Tax and the City Review - May 2024 Mike Lane and Zoe Andrews discuss: the Court of Appeal’s decisions in BlackRock (unallowable purpose and transfer pricing) and in Hargreaves Property (withholding tax on interest); changes to HMRC’s stamp taxes on shares guidance on the meanin...