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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
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC