A tricky issue in TUPE cases has always been what amounts to an undertaking for the purposes of the Regulations. This issue was eased to some extent from 6 April 2006 by the new TUPE regulations which state that TUPE always applies to Service Provision Changeovers, but the issue of whether something is an undertaking is still relevant in some cases (where there is no service provision changeover, for example the sale of part of a business). The EAT in Henry Convy & 9 Others v Saltire Press Ltd and Anderton Quay Printers Ltd provides a helpful summary of the case law giving guidance on this issue.