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Disguised remuneration
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Disguised remuneration
DISGUISED-REMUNERATION
The disguised remuneration regime unpacked
Karen Cooper
Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
Root 2 Tax: betting winnings or earnings?
Nigel Doran
Nigel Doran (Macfarlanes) examines the latest in a line of cases in which employer company and employee have tried to dress up earnings as a form of non-taxable payment.
Comment: Why the loan charge is unfair
Keith Gordon
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).
Comment: In defence of the ‘outstanding loan’ charge
David Pett
David Pett (
Temple Tax Chambers) argues that outstanding loan charges should be pursued
both as a matter of law and social policy.
When the loan charge bites: calculations and information requirements
David Pett
David Pett (Temple Tax Chambers) looks at the information requirements and how the disguised remuneration rules apply to the loan charge, and to later steps, if no settlement of earlier liabilities has been made with HMRC.
The 2019 loan charge and the human rights challenge
Gideon Sanitt
Gideon Sanitt (Macfarlanes) considers the human rights challenge by the Loan Charge Action Group against rules taxing historical employment related loans that are outstanding on 5 April 2019.
Disguised remuneration: the final nails in the coffin?
Liz Pierson
There are provisions tackling disguised remuneration in the Finance Act 2017, the Finance Bill currently going through Parliament, and for inclusion in the next Finance Bill. Liz Pierson (Squire Patton Boggs) reviews the legislative landscape.
Revised measures to be included in Finance (No. 2) Bill 2017
Claire Hooper
Claire Hooper (EY) outlines the government’s plans to re-introduce measures dropped from the pre-election Finance Bill and looks at the changes made to the previous draft.
Disguised remuneration: the new EBT loan charge
Nigel Doran
Ashley Greenbank
It seems that HMRC will finally achieve its objective of taxing all but the very oldest of loans made by EBTs by the end of 2018/19. Ashley Greenbank and Nigel Doran (Macfarlanes) explain.
Private client briefing for March 2017
Andrew Goldstone
Helen Cox
Andrew Goldstone and Helen Cox (Mishcon de Reya) review the latest tax
developments that matter affecting private clients.
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
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Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
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A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
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The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others