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EMPLOYMENT TAXES


Nigel Doran and Philip Swinburn (Macfarlanes) examine the Upper Tribunal decision on the employment-related securities provisions of ITEPA 2003 Part 7.
David Whiscombe (BKL) examines the tax issues surrounding an acquisition of shares by an employee in their employer company, and he contends that they are ‘from’ the employment less often than is commonly assumed.

New figures show that HMRC is ramping up investigations into footballers, agents and football clubs. In particular, the number of investigations into footballers has tripled in the year to March 2020. The main areas of focus are payments made for players' image rights and the tax treatment of agents' fees. 

Dominic Stuttaford and Sofia Casselbrant-Multala (Norton Rose Fulbright) review the NICs treatment of bonus payments by LLP to former employees who subsequently become members.
The scope of negative earnings is almost certainly wider than has generally been appreciated, writes Nigel Doran (Macfarlanes).
Contrary to HMRC’s guidance and CEST tool, mutuality of obligation is pivotal to determining employment status in surprising ways. Derek Francis (Terra Firma Chambers) examines cases showing how.
Thomas Dalby (Markel Tax) discusses state aid issues in relation to the enterprise management incentive scheme.

Sarah Hewson (EY) explains the extent of the tax exemptions on home working equipment.

Dominic Stuttaford and Susie Brain (Norton Rose Fulbright) examine the Court of Appeal decision.
Non-UK resident clients with no UK permanent establishment that engage UK-based workers through intermediaries to carry out work for them should not be subject to the new rules, write Philip Gilliland and Stephen Pevsner (Proskauer).
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