A ranking table of the competitive performance of investment managers/funds in, for example, a performance survey such as CAPS (Combined Actuarial Performance Services) or WM (World Markets).

An investment benchmark implicitly defined to be the average asset allocation of an investment manager's competitors.

P2P refers to networks that facilitate direct connections among individual nodes rather than through a centralized server. However, many famous P2P networks, such as 'Napster', actually relied on a central server to connect users.

The exchange of routing announcements between two Internet Service Providers for the purpose of ensuring that traffic from the first can reach customers of the second, and vice versa. Peering takes place predominantly at IXPs (Internet Exchange Points) and usually is offered either without charge or subject to mutually agreed commercial arrangements.

Law360, London: Peers voted once more on 2 June 2025 to introduce an amendment to the Data (Use and Access) Bill (DUA Bill) requiring AI companies to be transparent about the copyright-protected works they are training data on, in the third round of pingpong over the issue.

a form of particle accelerator

Income Tax Special Purposes Commissioners v Pemsel [1891] AC 531

A warning endorsed on a court order notifying the recipient against whom the order is made that he is liable to be committed to prison should he breach the order.

The senior accounting officer (SAO) regime was introduced by Schedule 46 to the Finance Act 2009 (FA 2009) with the aim of ensuring that qualifying companies have adequate tax accounting arrangements in place so that the correct tax liabilities are reported to HMRC. The regime applies to financial years beginning on or after 21 July 2009. The aim of the regime is supported by: • a qualifying company's obligation to notify HMRC of the identity of its SAO or, if there were successive SAOs for the relevant financial year, each individual that was the SAO for any part of that year • the SAO’s obligation, referred to as the SAO’s main duty, to take reasonable steps to ensure that the qualifying company has appropriate tax accounting arrangements in place • the SAO's obligation to file a certificate for each financial year confirming that the company had appropriate tax accounting arrangements or, where that was not the case, explaining the deficiencies and (although not legally required) often also including what steps are being

The imposition of penalties on enablers of defeated tax avoidance schemes is designed to prevent and discourage designers, marketers and facilitators of abusive tax avoidance schemes and arrangements. The introduction and expansion of this legislation is part of a broader government drive over a number of years to eliminate tax evasion and aggressive tax planning. Further initiatives in this area include the general anti-abuse rule (GAAR), issuing promoters of tax avoidance schemes (POTAS) with conduct notices, the imposition of criminal offences on promoters and offshore tax evaders and the introduction of a further revised version of the Professional Conduct in Relation to Taxation guidance. See General principles of tax avoidance—Private Client—overview for further information. When are the rules in effect? The legislation applies when both the arrangements which are entered into by the taxpayer and the enabling activity are entered into on or after 16 November 2017. Changes to Schedule 16 to the Finance (No 2) Act 2017, Sch 16 as introduced by FA 2021, ss 123(2), (3) and (13), have effect

FORTHCOMING CHANGE relating to penalty reform calls for evidence and behavioural penalties consultation: Building on a previous 2021 call for evidence, on 15 February 2024, HMRC published a further call for evidence entitled The Tax Administration Framework Review: enquiry and assessment powers, penalties safeguards, which included potential options for the reform of penalties, including the reform of penalty suspension and penalty escalation for continued or repeated non-compliance. On 30 October 2024, HMRC published the outcome of the call for evidence providing a summary of responses and the government’s next steps. Following up on this, at Spring Statement 2025 on 26 March 2025, the government published a consultation on behavioural penalties reform in relation to penalties for inaccuracies in returns and failure to notify. The consultation proposes two different approaches for reform of these penalty regimes: (1) reforming the existing framework but simplifying how penalties are calculated and applied, and (2) exploring an alternative model for a more fundamental redesign, including a proposed clear division between the penalty charged for inaccuracies

FORTHCOMING CHANGE relating to penalty reform calls for evidence and behavioural penalties reform: At Budget 2025, the government published a summary of responses to the consultation launched at Spring Statement 2025 on behavioural penalties reform and announced its intention to proceed with proposals to reform penalties for inaccuracies in tax returns and for failures to notify chargeability. This consultation followed two calls for evidence: • an initial call for evidence on ‘The Tax Administration Framework: Supporting a 21st Century tax system’ on 23 March 2021 and a summary of responses on 30 November 2021, and • a second call for evidence on ‘The Tax Administration Framework Review–enquiry and assessment powers, penalties, safeguards’, on 15 February 2024, followed by a summary of responses on 30 October 2024—this second call for evidence included potential options for the reform of penalties, including the reform of penalty suspension and penalty escalation for continued or repeated non-compliance The consultation outcome published at Budget 2025 sets out the government’s intention to develop draft legislation