The Freshfields Podcast

Tax Matters: Autumn Budget 2024 – Delivering difficult decisions

The UK Chancellor of the Exchequer, Rachel Reeves, has delivered the Autumn Budget 2024.

In the first Budget delivered by the Labour Party since 2010, Reeves announced an extensive array of tax reforms designed to 'stabilise' public finances and facilitate increased government spending.  Altogether, tax rises totalling £40 billion were announced - some expected, others less so.

In our latest podcast Peter Clements, Sarah Bond, Rose Swaffield, Josh Critchlow and Chris Gotch from our London tax team discuss the tax measures they found the most noteworthy in the Autumn Budget 2024, including:

• Headline Budget announcements, including:
  
  • increases in the capital gains tax (CGT) main rates and reforms to business asset disposal relief and investors' relief, accompanied by anti-forestalling measures;
  • an increase in employer National Insurance contributions by 1.2% from April 2025; and
  • an increase in the CGT rates for carried interest from April 2025, with more significant reforms expected to follow;
• Publication of the Corporate Tax Roadmap designed to provide stability for businesses and foster inward investment, including:
  • capping the headline UK corporation tax rate at 25%;
  • confirmation the permanent 'full expensing' capital allowance regime and existing R&D reliefs will be retained; and
  • plans to provide increased tax certainty to investors in major projects;
• Measures designed to 'close the tax gap', including:
  
  • an increase in the interest rate for unpaid tax;
  • targeted anti-avoidance measures applying with immediate effect; and
  • the recruitment of additional HMRC compliance and debt management staff; and
• Other changes to the UK's tax code, including:
  
  • confirmation the UK will introduce the Pillar Two undertaxed profits rule (the 'UTPR') for accounting periods from January 2025, along with the related repeal of the offshore receipts in respect of intangible property (or 'ORIP') rules;
  • the replacement of the remittance basis of taxation for non-UK domiciled individuals ('non-doms') with a new residence-based regime; and
  • confirmation of increases to the rate and duration of the Energy Profits Levy and the removal of the associated investment allowance.

Essential Antitrust #42: HSR rules changes: how to successfully navigate the new US merger control filing

On October 10, 2024 the US Federal Trade Commission (FTC) and the US Department of Justice (DOJ) issued a final rulemaking implementing the most significant update ever to the US HSR merger control filing. While these changes won’t be effective until the end of January 2025 at the earliest, understanding now how tackle new features such as expanded document requirements and new substantive narratives will position companies and dealmakers alike to hit the ground running. 

In this edition of the Essential Antitrust podcast, host Jenn Mellott is joined by fellow antitrust partners Mary Lehner and Bruce McCulloch, as well as Sebastian Fain, Global Transactions partner, to discuss the key changes that parties will have to contend with starting in early 2025.

No Worse Off #8: LMEs in England

In our latest podcast episode, Freshfields partner Lindsay Hingston and Senior Associate Alex Thomson are joined by Georgina Peters, Barrister at South Square, for a further look at of Liability Management Exercises (LMEs).

They examine how LMEs might be shaped by different legal regimes, with a particular focus on potential issues under English law.

Stay tuned for more insights into the world of restructuring and thank you for listening to “No Worse Off”.

Episode #3: EU elections - What you need to know about the von der Leyen II Commission

As we enter the final stretch of the set up of a new European College of Commissioners, tune into our latest EUnpacked podcast to hear insights from our policy team on the ground in Brussels. Together they discuss what the new Commission structure reveals about what lies ahead, who are likely to be the big personalities driving forward policy and legislation, and what steps remain to be taken before they take office later this year.

Out of the shadows: The growing regulatory spotlight on private capital

Over the past few years, the function and scope of private credit within financial markets has increased greatly. As private credit funds play a greater role in activities traditionally undertaken by banks, they are attracting growing scrutiny from both regulators and governments who are concerned about heightened risks to the financial system.

In this special podcast, a selection of senior Freshfields lawyers from different jurisdictions explore the increasing regulatory scrutiny of private credit across the world. Matt O'Callaghan, a partner in the firm’s Hong Kong office and head of the financial services regulatory team in Asia, hosts an insightful discussion featuring Nariné Atamian from Freshfields in New York, Greg King in London, and Theresa Kreft in Munich, in which they look beyond the headlines and share their perspectives on the changing regulatory landscape.

No Worse Off #7: Women in Restructuring

In our latest podcast episode, Freshfields partner Lindsay Hingston hosts a candid discussion on the subject of women in restructuring, featuring Katharina Crinson, counsel at Freshfields, and Jo Hewitt, managing director at Alvarez & Marsal.

Drawing on personal experience as well as insights from Katharina and Jo’s former and current leadership roles for the London chapter of the International Women's Insolvency and Restructuring Confederation (IWIRC London), they explore their career journeys in a field where women are still under-represented, the importance of gender diversity, and strategies for promoting an inclusive industry.

Stay tuned for more insights into the world of restructuring and thank you for listening to “No Worse Off”.

No Worse Off #6: Liability management

The sixth episode of our restructuring podcast series, No Worse Off, which provides legal and commercial insights, and practical tips, on the world of restructuring.

Liability management has become a key strategy in the US distressed markets as the restructuring community seeks alternatives to bankruptcy.  These transactions can enhance liquidity, restructure debts, and extend runway via an out-of-court process.

In this episode, we are bringing together our experts from our London, New York and Hong Kong offices to discuss the nuances of liability management, the opportunities it presents for creditors, and its potential for growth in European and Asian markets.

Stay tuned for more valuable discussions and expert advice in the upcoming episodes of “No Worse Off”.

Essential Antitrust #41: Vertical restraints enforcement: trends to watch

Two years have elapsed since the introduction of new vertical block exemptions and guidelines in the EU and the UK. Since then, the European Commission has imposed the highest record fine on file for unlawful territorial restrictions imposed by a supplier on its resellers, in contravention of EU competition law. On the opposite side of the Atlantic, key developments in the US include increased enforcement of vertical restraints by US antitrust agencies.

In this episode of our Essential Antitrust podcast, host Jenn Mellott is joined by fellow antitrust partners Charlotte Colin-Dubuisson, Meghan Rissmiller and Al Mordaunt to discuss recent enforcement trends in the EU, the UK, the US and Asia.

Navigating Cybersecurity Risks in the Healthcare Sector

The healthcare industry is one of the most vulnerable sectors to cybersecurity risk. In this episode of the MedTech podcast, Freshfields partners Vinita Kailasanath and Brock Dahl explore some recent examples of credible threats to the industry and how companies can implement technological innovation to help mitigate these risks.

Episode #2: EU elections - A business outlook

In this second episode of our EUnpacked podcast series that looks at key hot topics being tackled in Brussels, podcast host Natalie Pettinger Kearney is joined by her colleagues Léa Bareil and Victor Garcia Lopez to talk about the EU elections and what it means in terms of the outlook for business.