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EMPLOYMENT TAXES
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.
Comment: Why we need a new disguised remuneration settlement opportunity
Sarah Gabbai
The government should take a more pragmatic approach to taxpayers affected by
the loan charge, writes Sarah Gabbai (McDermott Will & Emery).
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
Reporting of offshore interest
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC