Fehzaan Ismail and Aimee Rotherforth (EY) consider how the statutory provisions relating to unpaid cash remuneration may impact ordinary commercial reorganisations.
A UK corporation tax ‘101’ for employee remuneration is that accrued cash bonuses which are unpaid within nine-months from the end of the relevant period of account are to be left out of account until the point in time at which these are paid. For these purposes an amount is ‘paid’ at the point at which it is treated as received by an employee for the purposes of UK income tax. The statutory provision which governs this is CTA 2009 s 1288. In the case of a standalone company with no break or change in its trade this provision would generally be expected to give rise to an equitable outcome.
Complications arise in the context of unpaid cash bonuses where there is a relevant change between...
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Fehzaan Ismail and Aimee Rotherforth (EY) consider how the statutory provisions relating to unpaid cash remuneration may impact ordinary commercial reorganisations.
A UK corporation tax ‘101’ for employee remuneration is that accrued cash bonuses which are unpaid within nine-months from the end of the relevant period of account are to be left out of account until the point in time at which these are paid. For these purposes an amount is ‘paid’ at the point at which it is treated as received by an employee for the purposes of UK income tax. The statutory provision which governs this is CTA 2009 s 1288. In the case of a standalone company with no break or change in its trade this provision would generally be expected to give rise to an equitable outcome.
Complications arise in the context of unpaid cash bonuses where there is a relevant change between...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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