This Practice Note provides practical guidance on the usage of the security exception, as set out in the General Agreement on Tariff and Trade 1994 (GATT), for a World Trade Organization (WTO) Member State to unilaterally increase tariffs. The Practice Note provides guidance on the principles applicable to bound tariffs as well as the security exception. It does so by reference to the unilateral duties imposed on steel and aluminium products by the United States of America (US). Introduction In February 2025, the President of the United States of America announced that the US will: • reinstate the full 25% tariff on steel imports. This follows the 2018 introduction of the 25% duty on steel imports, although in that instance, countries could be exempted from the increase in tariffs. Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korean, the EU, Ukraine and the UK were exempted. This reinstatement applies to all imports of steel product, irrespective of the origin of the steel products • increasing the tariffs on aluminium imports to 25%. This follows the 2018 introduction

This Practice Note considers how you might set about improving your staff's financial awareness so they might be more inclined to, and more skilled at, ensuring you hit your financial targets. Financial awareness—why it should matter to fee earners? It is not sustainable to have knowledgeable fee earners who provide an excellent service to clients but who make no profit from their efforts. To make a good profit, your fee earners will need to know the law and be attentive to the needs of every client but these skills alone will not guarantee a profit. Lawyers who understand the finances of a law firm can meet clients' expectations and at the same time deliver high levels of profit to the firm. This means the firm can invest in its fee earners and clients to create even higher levels of profit. Fee earners who are commercially minded are also more likely to give good commercial advice to their clients rather than advice that is just technically correct. What

This Precedent Raising the profile of your in-house team—team brand workshop contains a PowerPoint team brand workshop template and accompanying notes to help you run a workshop with your team to determine what key activities and values you wish to be known for in your business. It takes you and the team through the process of sharing and refining ideas before creating some concrete actions and next steps. 1 Meeting logistics Let the team know ahead of time that this will be a working session and ask them to think about how they add value to the business and to come along prepared to share their opinions. Make sure you have at hand paper, a pack of sticky notes per person, marker pens for all and an area in a room where you can put things up on the wall. Plan on two and a half hours for the meeting, including a 15-minute comfort break halfway through (based on five to ten attendees). Appoint someone in the team to help with timekeeping and making a list of actions,

This Practice Note contains top tips for raising the profile of your in-house legal team within your company. Understand the business goals and strategy Work with senior stakeholders, such as general managers/managing directors, department and functional heads, to understand their objectives and timeframes. Ask them about their expectations of the legal team and for any ideas they have on how you could improve or evolve the service they currently receive. Create a vision of what and how your team delivers Once you have enough input from senior stakeholders, form your own vision of what you think your team should stand for and how it should deliver to the business. Write this down and take some time to refine it and test it, first with your manager or a mentor and then with your stakeholders. Work with your team to design your collective brand Get your team involved. Set up some time to host a brainstorming workshop or workshops where you share your vision

The Financial Conduct Authority (FCA) has announced that Rajinder Gill and accomplices have been sentenced for their involvement in a sale-and-rent-back scheme which targeted struggling homeowners. Gill has been sentenced to two and a half years in prison for running a scheme without being authorised and illegally providing credit agreements and mortgages. Sale‑and‑rent‑back schemes involve homeowners selling their property, often at a discount, with an agreement to stay in their home as tenants paying rent. The FCA says such schemes are usually a last resort for people facing debt or repossession and are considered high risk, and firms offering them must be authorised by the regulator.

STOP PRESS: A revised version of the National Planning Policy Framework was published on 17 August 2026. This content is being reviewed in light of the revised version. UNESCO supports the Ramsar convention on the conservation and use of wetlands. UNESCO estimates that more than 64% of the world’s wetlands have disappeared since the beginning of the last century. In most regions across the world, wetlands continue to decline compromising the benefits that wetlands provide to people. Wetlands are areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres. Ramsar sites are wetlands of international importance, designated under the Ramsar Convention. Ramsar sites may also incorporate riparian (banks of a stream, river, pond or watercourse) and coastal zones adjacent to the wetlands, and islands or bodies of marine water deeper than six metres at low tide lying within the wetlands. Ramsar Convention The Ramsar Convention

Lexis+® UK Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed are those of Lexis+® UK Tax. This Practice Note has subsequently been reviewed and updated by Aparna Nathan, KC, Devereux Chambers. The Ramsay principle is an approach to statutory interpretation that has been developed by the courts in cases involving tax avoidance. For a general introduction to the Ramsay principle, see Practice Note: Ramsay as a guide to statutory construction. This Practice Note is about cases in which the courts have applied the Ramsay principle in order to take a realistic view of what have become known as composite transactions, ie transactions that involve a number of steps, designed to operate together to produce a particular outcome. Other themes that have developed in cases in which a Ramsay analysis has been applied to the facts are discussed in Practice Note: Ramsay—reality and legal form. Composite transactions have, broadly, been divided into two categories: • circular, self-cancelling transactions—transactions undertaken purely for tax

Lexis+® UK Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed are those of Lexis+® UK Tax. This Practice Note has subsequently been reviewed and updated by Aparna Nathan, KC, Devereux Chambers. This Practice Note describes two cases (Macniven v Westmoreland, and Mayes) that demonstrate that the Ramsay principle may not be effective to defeat tax planning that is based on highly prescriptive and/or technical legislation. Even if the transactions are self-cancelling and tax-motivated, there may be no purposive construction of the legislation that is sufficient to counter the scheme. The background to the Ramsay principle is described in Practice Note: Ramsay as a guide to statutory construction. As the courts have developed the Ramsay principle, a number of different aspects of the principle have emerged. One of these aspects is that some taxing statutes use such technical and/or prescriptive language that Ramsay does not apply, in the sense that it does not change the tax treatment of the transactions

Lexis+® UK Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed are those of Lexis+® UK Tax. This Practice Note has subsequently been reviewed and updated by Aparna Nathan, KC, Devereux Chambers. The Ramsay principle (or Ramsay doctrine) refers to an approach to statutory interpretation that has been developed by the courts in cases involving tax avoidance. It began with the landmark decision by the House of Lords in WT Ramsay in 1981. The principle was restated by the House of Lords in BMBF v Mawson in 2004, and a result some cases refer to the principle by reference to BMBF (or Mawson) rather than Ramsay, but for consistency this Practice Note, and its related Practice Notes, refer to the Ramsay principle. The Ramsay principle can, with a large amount of generalisation, be summarised as: • look at the law—what did Parliament intend when it chose those words? • look at the facts—should an individual transaction,

The following table lists, in reverse chronological order, cases that have been important in the development of the Ramsay anti-avoidance principle. It is not a list of every case that has discussed the principle. It is weighted towards the present in the sense that decisions of lower courts are more likely to feature in the list if they are relatively recent, and so demonstrate the latest judicial thinking. For a general introduction to the Ramsay principle, see Practice Note: Ramsay as a guide to statutory construction. For comprehensive tax case tracking across current (and recently completed) tax cases, see the: Tax—cases tracker. Case name and citation Who won in the highest court? Facts in a nutshell Quote(s) from the judgment Comment Grand Smile Design Ltd [2026] UKFTT 1248 (TC) (judgment date 26 August 2026) Loan charge ‘Having regard to the overall purpose of para 11, it is reasonable to infer that the legislature intended a “payment made in money” to fall within para 11(4)(b) only if, and to the extent that, in making it

Lexis+® UK Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed are those of Lexis+® UK Tax. This Practice Note has subsequently been reviewed and updated by Aparna Nathan, KC, Devereux Chambers. The background to the Ramsay principle is described in Practice Note: Ramsay as a guide to statutory construction. The courts have refined the Ramsay principle over time so that in Arrowtown Assets it was possible for Ribeiro PJ to sum it up in one sentence: 'the ultimate question is whether the relevant statutory provisions, construed purposively, were intended to apply to the transaction, viewed realistically.' This summary has been quoted approvingly in many later cases (such as BMBF). It is striking that the summary does not refer to tax avoidance, despite the fact that this is the context in which the Ramsay principle has been developed. Earlier expressions of the principle, such as in Lord Brightman's judgment in Furniss v Dawson, expressly confined it to tax avoidance

Tax analysis: In HMRC v Altrad Services Ltd and another, the Court of Appeal (CA) overturned the decision of the Upper Tribunal (UT) (which had itself overturned the decision of the First-tier Tax Tribunal (FTT)) in finding that a disposal of assets as part of a series of pre-ordained steps in a ‘tax scheme’ did not result in the taxpayers ‘ceasing to own’ the assets in question for the purpose of section 61 of the Capital Allowances Act 2001 (CAA 2001). The case poses interesting questions for tax practitioners around when an asset ceases to be owned and also highlights the reliance of HMRC and the courts on the Ramsay principle despite more recent case law and the GAAR. Written by Matt Marfani, associate director, and Mark Bevington, principal, at ADE Tax.