STOP PRESS relating to MTT and DTT legislation in Finance Act 2026: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International. STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based

STOP PRESS relating to MTT and DTT legislation in Finance Act 2026: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International. STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based

STOP PRESS relating to MTT and DTT legislation in Finance Act 2026: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International. STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based on previous tranches

STOP PRESS relating to MTT and DTT legislation in Finance Act 2026: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International. STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based on previous

STOP PRESS relating to MTT and DTT legislation in Finance Act 2026: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International. STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based on previous

Arbitration analysis: Christopher Hancock QC, sitting as a deputy judge in the Commercial Court, dismissed three applications made pursuant to sections 67 and 68 of the Arbitration Act 1996 (AA 1996) challenging awards on the basis of the arbitrator’s lack of jurisdiction and the procurement of awards by fraud. The LCIA awards in question were made in the same arbitration proceedings by an experienced sole arbitrator. The decision is of particular interest to practitioners in its examination of the scope of arbitrators’ jurisdiction following orders for remission and the difficulty in challenging an award on the basis of a serious irregularity where a fraud has been proved, but substantial injustice cannot be shown.

MLex: Meta Platforms, TikTok and LinkedIn can all expect preliminary data protection decisions against them to be finalised and sent to the European Data Protection Board (EDPB) for scrutiny this summer, Ireland’s Data Protection Commission (DPC) has said. The DPC said it has made progress in multiple major cases against Big Tech companies, with those closest to completion being those into TikTok in relation to data transfers to China, LinkedIn regarding targeted ads, and Meta about security.

Dispute Resolution analysis: Mrs Justice O’Farrell DBE, found that a different dispute had been resolved in a second adjudication where the adjudicator was asked to carry out a valuation of the works. Daniel Goodkin of 4 Pump Court Chambers considers the judgment and its implications.

Employment analysis: A candidate with Asperger’s syndrome was discriminated against by being required to sit a multiple choice ‘Situational Judgment Test’ as part of a competitive recruitment process. The requirement to sit the test, and the candidate’s failure to proceed to the next stage of the process due to an inadequate test result, amounted to indirect discrimination, failure to comply with the duty to make reasonable adjustments and unfavourable treatment because of something arising in consequence of disability, according to the EAT.

PI & Clinical Negligence analysis: The court held that it was impermissible for some 3,500 individual claimants, all seeking damages against the Ministry of Defence (MOD) for noise-induced hearing loss (NIHL) allegedly caused by their military service, to be included on a single claim form, for which one issue fee was paid. Instead, a separate claim form had to be issued for each claimant, and individual issue fees paid. The court’s decision was consistent with the approach previously taken in Turner v MOD and Bargh v MOD. The administrative and financial burdens on those seeking to bring claims on behalf of a cohort of individuals with disparate claims should not be overlooked. The position is not different under a formal group litigation order (GLO). ‘Omnibus’ or ‘bulk’ claim forms containing numerous claimants with disparate claims are vulnerable to being struck out. Written by Peter Houghton, barrister at Crown Office Chambers.

Dispute Resolution analysis: overturning an order for permission to serve out of the jurisdiction, Purle QC highlights issues to consider when seeking to bring proceedings against multiple defendants, where some are based in England but there is an exclusive jurisdiction clause in favour of another jurisdiction. The starting point is the exclusive jurisdiction clause and weighty evidence will be required to enable the proceedings to be commenced elsewhere. In this case, the court highlighted the ingenuity of counsel in their drafting of the pleadings, they were suggestive of a motive to bring proceedings in a different jurisdiction ie England, but held that they could not circumvent the application of the jurisdiction clause.

This Practice Note contains an outline of the rules that apply when multiple principals engage the services of appointed representatives (ARs). It introduces: • the general rule that permits an AR to engage more than one principal • the exceptions to that general rule • the requirements laid down by the Financial Conduct Authority (FCA) that must be met before an AR can act for multiple principals, and • the contractual terms that multiple principals must enter into prior to appointing an AR For further information, see Practice Note: Appointed representatives. The Financial Services and Markets Act 2000 (FSMA 2000) and the Financial Services and Markets Act 2000 (Appointed Representative) Regulations, SI 2001/1217 (the AR Regulations) do not prevent ARs from acting for more than one principal. However, under reg 3(1) of the AR Regulations, it is a requirement that the contract between the principal and the AR either prohibit the AR from representing other counterparties, or contain a provision enabling the principal to: • impose such a prohibition, or • impose restrictions as to the other counterparties