ARCHIVED: This Practice Note has been archived and is not maintained. Abolition of non-dom regime and introduction of residence-based IHT regime from 6 April 2025 Before 6 April 2025, the concepts of residence, domicile and deemed domicile were used to establish the extent of an individual's liability to UK income tax, capital gains tax (CGT) and inheritance tax (IHT) An individual who was UK resident and UK domiciled had the closest connection to the UK and was generally liable to income tax, CGT and IHT to the full extent of their worldwide income, gains and assets. In contrast, a person who was neither UK tax resident nor UK domiciled, incurred only a limited liability to UK tax on their UK situs assets. Those who were UK tax resident but non-UK domiciled were able to claim the benefit of the remittance basis of taxation in relation to their foreign income and gains. They were also able to avoid IHT on their non-UK situs assets. Finance

STOP PRESS: On 17 June 2025, the European Commission published its long-awaited review of the EU Securitisation Framework, accompanied by a comprehensive legislative proposal to amend the EU Securitisation Regulation (Regulation (EU) 2017/2402), the EU Capital Requirements Regulation (Regulation (EU) No 575/2013), the EU Solvency II Delegated Regulation (Commission Delegated Regulation (EU) 2015/35) and the EU Liquidity Coverage Requirement Delegated Regulation (Commission Delegated Regulation (EU) 2015/61). Amendments to the EU Securitisation Regulation relate to, among other things, risk retention, transparency, STS on-balance sheet securitisations and the definitions of public and private securitisation. Amendments to the Capital Requirements Regulation, relate to, among other things, risk-sensitive capital requirements, resilient securitisation positions and significant risk transfer tests. Further consultations and amendments are expected as the EU legislative process advances. Securitisation is a financing technique Securitisation is a technique used to facilitate investment in types of assets that would otherwise be difficult to invest in (ie 'illiquid' assets such as bilateral loans and mortgage and other loans to natural persons). In its most common and basic form securitisation

This Practice Note provides a basic introduction to security and covers the following: • what is security • why lenders take security • who can provide security • what types of assets can be the subject of security • what types of security can be given • what is perfection and why it is important to perfect security • other steps a lender can take to improve its position in the order of priority In this Practice Note, the term ‘security provider’ refers to the person or entity that grants the security over its assets. The term ‘secured party’ refers to the person or entity with the benefit of the security. The secured party will often be a lender under a loan and this Practice Note assumes that security is being taken in connection with a lending transaction. However, security can be provided for any type of debt. Introductory guide to security—key takeaways • Security interests grant rights over specific assets of a borrower or third party, giving lenders proprietary rights that

Scope of this Practice Note This Practice Note provides an introduction to security reviews and covers: • when and why a lender might ask its lawyers to carry out a security review • things to do before beginning a security review, and • how to report the results of the security review to the lender It forms part of a set of three documents dealing with carrying out and presenting the results of a security review, which should be used in conjunction with each other. The other two documents are: • a Security review checklist, which sets out the relevant searches and checks that should be carried out when conducting the security review, and • a Precedent: Security review report, which should be used to report the results of the security review to the lender Security reviews—when and why? Often the first step in a restructuring is for the lender to ask its legal advisors to conduct a full review of the loan and security documents relating to a particular borrower or

Stamp duty land tax (SDLT) For further detail on the meaning of a chargeable transaction including what a chargeable interest is and when it is acquired, see Practice Note: Land transactions, chargeable interests and chargeable transactions. Territorial scope of SDLT SDLT ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that date, land and buildings transaction tax (LBTT) applies to such transactions, subject to transitional provisions (see Scotland—land and buildings transaction tax (LBTT) below). SDLT ceased to apply to any land transaction involving any interest in or over land in Wales from 1 April 2018. From that date, land transaction tax (LTT) applies to such transactions, subject to transitional provisions (see Wales—land transaction tax (LTT) below). Consequently, references in this Practice Note to ‘UK land’ or similar expressions in the context of the application of SDLT should be read to exclude any interests in or over land in Scotland from 1 April 2015 and in or over Wales from 1 April 2018. For

What is it? Structured trade finance or structured commodity finance transactions are generally loan facilities under which funds are applied to produce, store, manufacture, sell or otherwise deal with goods or commodities. The money generated from the sale of those goods is used to repay the loan. In other words, they are structured to be self-liquidating. These transactions are invariably cross-border and require consideration of, among other things, the appropriate structure and type of security that can be taken, and the types of goods being financed. For example, if the product is crude oil, export licences may be required in some jurisdictions. As such, local legal advice will usually be required to ensure the transaction is properly structured from a local law perspective. Set out below are some of the different structures a financing can use. These are the most basic structures but they can be varied in a number of ways. For example, a loan can be bilateral (between a single lender and a borrower) or syndicated (between a group of lenders and a borrower).

This Practice Note is intended as an introductory guide to sustainable finance for transactional banking and finance lawyers in the UK and EU contexts. For an overview of the UK and EU regulatory landscape around sustainable finance, see Practice Note: Introductory guide to sustainable finance and ESG for finance lawyers—regulatory landscape. Detailed information on all areas of sustainable business, including the regulatory environment, can be found in our ESG and sustainability toolkit. This Practice Note explains: • what is meant by sustainable finance and environmental, social and governance (ESG) • key drivers of sustainable finance • key sustainable finance products, including sustainability-linked and green loans, bonds, securitisations and derivatives • the challenges facing the market, such as disclosure and ‘greenwashing’ • information on the approaches of the market and the main industry bodies, and where to find practical guidance on documentation issues What is meant by sustainable finance and ESG? Opinions regarding what constitutes sustainable finance differ, but a helpful explanation of what is meant by

STOP PRESS: On 21 April 2026, the Commission adopted two delegated regulations supplementing the ESG Ratings Regulation: one with regards to regulatory technical standards (RTS) specifying the elements of ESG rating products to be disclosed to the public and to users of ESG ratings, rated items and issuers of rated items; the other with regards to RTS specifying the measures and safeguards to be implemented by ESG rating providers to separate their ESG rating activities from their other activities. Both regulations shall enter into force on the 20th day following that of their publication in the Official Journal of the European Union and apply from 2 July 2026. This Practice Note provides a high-level overview of the regulatory landscape and underlying policy objectives relating to sustainable finance in the UK and EU. It is intended as additional guidance to Practice Note: Introductory guide to sustainable finance and ESG for finance lawyers and does not cover specific drafting or disclosure requirements to be included in transaction

STOP PRESS: The UK’s prospectus regime is currently based on the EU Prospectus Regulation, which was retained in UK law after Brexit as the UK Prospectus Regulation. The UK has been reviewing its prospectus regime as part of wider efforts to reform the capital markets in the UK and enhance the attractiveness of the UK as a listing venue. As part of this, the UK Prospectus Regulation will be replaced by the Public Offers and Admission to Trading Regulations 2024 (the POATRs), with all detailed requirements relating to admission to trading to be covered in Financial Conduct Authority (FCA) admission rules. The FCA published a consultation paper (FCA CP24/12) which closed in October 2024, setting out detailed proposals. A second consultation paper (FCA CP25/2), covering, among other things, retail bonds; a single disclosure framework for debt securities, further issuances and abolition of Listing Particulars, was published on 31 January 2025. The consultation closes on 14 March 2025. Final FCA rules are expected by the summer of 2025 (to take effect by early 2026). For further

The taxation of trusts is based on the personal tax regime. Trusts are subject to the same taxes as individuals (income tax, capital gains tax (CGT) and inheritance tax (IHT)) but the application of those taxes varies according to the status and terms of the trust. The most important factor in determining the tax treatment of the trust will be to establish what type of trust it is (ie what the entitlement of the beneficiaries is). Other relevant factors relevant to the tax treatment of a trust include the date of commencement of the trust, the age of the beneficiaries and whether it was created during lifetime or on death. Therefore, the first step in working out how a trust is to be taxed is to read the trust documents (including the trust deed and any ancillary documents such as subsequent deeds of appointment) to assess what type of trust it is. Whether or not an interest in possession subsists must be determined in order to apply the correct tax treatment (although

Introduction What is trade finance? The term 'trade finance' is used to cover a number of different forms of financing and methods of payment, including the use of secured syndicated financings and letters of credit. Broadly speaking, trade finance is used by buyers and sellers of goods internationally to provide credit support for the different stages of the sourcing, production and sale of goods and commodities. The term ‘trade finance’ covers structured and unstructured transactions. Structured transactions are where a borrower (usually a producer or seller of goods) receives a loan to finance the production/processing of the goods, or for cash flow purposes. This loan has some form(s) of security and structure of cash flows. A typical structure would result in the loan being repaid by the sale proceeds of the goods. Forms of structured trade finance include pre-export finance, prepayment finance, tolling, borrowing base financing, reserve base lending and warehouse finance. See Practice Note: Introductory guide to structured trade finance for further details. Unstructured trade finance is typically a way of financing trade (usually to

ARCHIVED: This Practice Note has been archived and is not maintained. A landlord can only end an introductory tenancy by obtaining and executing an order of the court for possession. The landlord has a mandatory right to possession and it is not necessary to establish one of the grounds for possession. However, an order cannot be made unless the introductory tenancy notice requirements are satisfied. Notice of Proceedings for Possession A landlord must serve a Notice of Proceedings for Possession on the tenant stating: • that it will ask the court for an order for possession • the reasons for the possession order • the date after which possession proceedings may be begun • that the tenant has the right to review the landlord’s decision • the date by which a review request must be made • that the tenant can seek advice from a Citizens' Advice Bureau, a housing aid centre, a law centre, or a solicitor There is no prescribed form for a