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What happens when a Lender fails to fund?

In this briefing we explore the risk that a lender might renege (voluntarily or involuntarily) on its funding commitments. We touch on the different types of lender entities in the market currently and examine why there are often different reasons behind such a failure to fund.

Internationally Mobile Employees part 1 – general overview

Overview of the key concepts and issues to be aware of for both non-UK employers and UK employers with mobile employees coming to the UK to work and for employees working abroad. The session covers Pay As You Earn (PAYE), National Insurance Contributions (NICs) and immigration issues as well as going through illustrative examples.

Issues in crypto insolvency

In this podcast Jonathan Gilmour, Peter Hughes, John Lee and Adam Schnider consider the implications of the recent collapse of cryptocurrency exchange FTX. They discuss some of the key issues that could arise from the insolvency of FTX or other crypto investment firms more generally, including priority of claims, proprietary rights in crypto-assets, tracing and recovery of crypto-assets, and cross-border insolvency issues.

Case law update: Purpose test

HMRC v. Blackrock [2022] – Upper Tribunal decision on application of loan relationships unallowable purpose rule and transfer pricing rules to a debt pushdown structure.

Burlington v. HMRC [2022] First-tier Tribunal decision on the application of treaty purpose test applicable to the UK/Ireland double tax agreement.

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