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Inside HMRC’s Transfer Pricing Enquiries

HMRC’s transfer pricing yield nearly doubled to £3.39 billion in a single year. A once-in-a-generation legislative reform took effect on 1 January 2026. The Court of Justice of the European Union (CJEU) has ordered €14 billion recovery from Apple. If you have cross-border related-party transactions and UK operations, this is the moment to act, not...

Navigating AI Hallucinations in the Legal Profession

Artificial intelligence (AI) is starting to play a more visible role in legal practice. As these tools become more capable, the key issue is not whether they will be used, but how. In particular, where do we draw the line between the use of AI as a tool and the provision of legal advice for...

Directors in HMRC’s Crosshairs: A Landmark Ruling on VAT Fraud Penalties

A significant Upper Tribunal decision handed down on 26 February 2026 has important implications for directors of companies that have been, or may be, subject to VAT fraud investigations. The case of Ashley Charles Trees v HMRC [2026] UKUT 00092 (TCC) clarifies the limits of HMRC’s power to pursue individual directors for civil evasion penalties...

Director’s Loan Accounts and Liquidation: When is a Debt Written Off?

Lessons from Quillan v HMRC [2025] UKFTT 421 (TC) Introduction If you are a director of a close company, or advise one, the tax treatment of an overdrawn director’s loan account (“DLA”) when the company enters liquidation is an issue that can have significant and sometimes unexpected financial consequences. A recent decision of the First-tier...

Kittel Assessments: The Evolving Landscape of VAT Fraud Enforcement in the UK

Introduction The Kittel principle has become one of HMRC’s most powerful weapons in combating VAT fraud, allowing the tax authority to deny input tax deductions to businesses that knew or should have known their transactions were connected to fraudulent VAT evasion. Named after the European Court of Justice’s decision, the principle states that a taxpayer...

Understanding the Kittel Principle and HMRC’s VAT Fraud Enforcement

If you have received a Kittel assessment from HMRC or require strategic advice to mitigate VAT fraud risks, please contact us. Our team brings over 20 years of experience in this area, having acted in a number of leading cases in the Tax Tribunal, High Court and Court of Appeal. Kittel Principle The Kittel principle, established...

Data Privacy & AI Regulatory Developments

The increasing presence of AI models in everyday life means that regulatory and risk concerns have burgeoned. There are risk-related, legal and ethical issues surrounding chatbots; profiling and business applications. Additionally, with increasing access for everyone to AI written, verbal, facial and visual/artistic models, we need to be concerned with fake news; plagiarism; breaches of...

The International Sports Law Conference 2024

In October 2024, Agnieszka Kalinowska (an equine and sports specialist of W Legal) participated in the International Sports Law Conference (“the Conference”) organised by the worldwide association of sports lawyers: International Sports Lawyers Association (“ISLA”), Instituto Iberoamericano de Derecho Deportivo and Portuguese Sports Law Association.   The Conference took place at the magnificent Sport Lisboa...

A Cry for Clarity: Isabel Dos Santos v Unitel S.A.

In recent years, English Courts have seen considerable discussion around the interpretation of the “good arguable case” standard—a critical test for granting a freezing injunction. However, conflicting judgments have applied inconsistent approaches to this test, which has often led to uncertainty about the required threshold. Bringing much-needed clarity to this grey area, the Court of...

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