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Employment taxes
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EMPLOYMENT TAXES
The Foreign Income and Gains regime: employer considerations
Nisus Larsen
Claire Murray
The UK is likely to become more attractive in the short term for overseas
employees but less attractive in the medium to long term, Claire Murray and
Nisus Larsen (Alvarez & Marsal) explain.
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The ERS deeming rule: clarity from the Supreme Court
Nigel Doran
While the Supreme Court judgment in
Vermilion
provides clarity on some of the questions raised by the deeming rule, it does not touch on questions raised by a number of other common scenarios, writes Nigel Doran (Macfarlanes).
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
EMI takes its turn in the spotlight
Claire Matthews
Tax-favoured share plans are firmly in the spotlight at the moment.
Claire Matthews (Taylor Wessing) reminds us how EMI options work and
reviews recent changes.
IR35: two media cases with different outcomes
Tom Wallace
Gary Lineker was successful at the tribunal, while Eamonn Holmes was not.
Thomas Wallace (WTT Consulting) explains why.
Murphy: earnings and settlement agreements
Joshua Carey
Sam Way
The Court of Appeal’s decision brings refreshed simplicity to a tortured area of the law, write Joshua Carey and Sam Way (Devereux Chambers).
Hoey: you’d better PAYE up
Hugh Gunson
Guy Bud
Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
The Court of Appeal’s guidance on IR35 employment status
Georgia Hicks
Georgia Hicks (Devereux Chambers) examines two cases which seek to give authoritative guidance on the application of the
Ready Mixed Concrete
and business on own account tests.
Business on own account?
Georgia Hicks
As we await two Court of Appeal decisions, Georgia Hicks (Devereux Chambers) considers what HMRC’s new approach on the ‘business on own account’ test could mean for taxpayers.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
Wealth taxes and fiscal reality