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How far does the fiction of a deeming provision extend? Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC. In its recent judgment, overturning the Court of Appeal’s decision, the Supreme Court held that a South African r... Subject access requests: new challenges arise from COVID-19 In the broader context of COVID-19, this briefing considers the ICO's draft guidance on the Right of Access, and offers some practical guidance for organisations in relation to DSARs. Although some organisations have seen a decrease in data subject a... Competition & Regulatory Newsletter On 6 May 2020 the UK Competition and Markets Authority announced its decision to block the completed acquisition of Footasylum plc by JD Sports Fashion plc following an in-depth Phase 2 investigation. The CMA noted the loss of competition between the par... Strings attached? Changes to the UK Government’s CCFF and CLBIL schemes to support large businesses This morning (19/5/2020) HM Treasury announced some important changes to the Covid Corporate Financing Facility (CCFF) and the Coronavirus Large Business Interruption Loan Scheme (CLBILS).  In this briefing we summarise the headline changes which in... New horizons: quantum computing and the banking sector In this article we provide a brief overview of the central tenets of quantum computing, before focussing on its potentially profound implications for the banking sector. The stage is set for quantum computing to bring about seismic changes in t... Getting the Deal Through - Debt Capital Markets (United Kingdom) 2020 UK and EU legal and regulatory framework of the debt capital markets, and factors which influence the market, including the documentation and execution of transactions. The UK has a very active debt capital markets known for their internationalism, ... Incentives Bulletin - April 2020 Budget; consultation on EMI schemes; annual capital gains tax allowance; COVID-19; IR35 reforms; interest on employment-related loans; “loan charge” review Topics covered in this bulletin: Recap on UK 2020 Budget Government consultation o... Hong Kong Uncertificated Securities Market Explained This update examines the latest proposals for implementing an uncertificated securities market in Hong Kong following the publication of an April 2020 conclusions paper. In January 2019, a joint consultation paper was published to examine the practicalit... Disclosure of rights attached to listed securities This briefing summarises the new requirement on issuers to disclose the rights and restrictions attached to their listed securities. In order to reduce the risk of market disruption occurring as a result of an issuer announcing an action that security ho... HMRC Preferential Creditor Status – Measure Delayed, for Now The Finance Bill 2020, which is currently scheduled for further debate by the UK Parliament from 27 April 2020, includes provisions to grant HMRC secondary preferential creditor status for certain taxes due from an insolvent business.