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The Supreme Court has handed down a significant judgment in HMRC v HFFX LLP [2026] UKSC 17, resolving a long-running dispute over the tax treatment of deferred remuneration arrangements used by partners of a foreign exchange trading LLP. The case turned on an elaborate profit-sharing structure known as a Capital Allocation Plan (CAP), under which...

W Legal is pleased to announce its successful representation of a claimant in High Court proceedings involving the misappropriation of approximately 32.46 Bitcoin, valued at over £1.7 million. The proceedings were brought against Person Unknown, alleged to have operated under the alias “Brian Smith”, and also against Huobi Global S.A. (HTX), a leading cryptocurrency exchange....

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...

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...

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...

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...

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...

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...

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...

We are pleased to share that Nigel Kushner, Amanda Wick, Agnieszka Kalinowska, and Raf Demczuk represented W Legal at the 11th Annual Compliance and Anti-Money Laundering (AML) Conference in Warsaw, Poland. As part of the event, Nigel Kushner and Amanda Wick were featured speakers on the panel discussion, “From Policy to Pressure: The Evolution of...