ACCELERATED-PAYMENTS

Karen Cooper

Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.

Geoff Lloyd

Dan White

Geoff Lloyd and Dan White (EY) examine recent court decisions which tend to favour HMRC’s application of the FN and APN provisions.

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.

Gideon Sanitt

In Pitcher, the tribunal has considered HMRC’s entitlement to issue a penalty following non-payment of an accelerated payment notice. Gideon Sanitt (Macfarlanes) reviews the impact of that decision.

Jeanette Zaman

James Hume

Jeanette Zaman and James Hume (Slaughter and May) consider how the financial product hallmark has expanded the circumstances in which DOTAS

is potentially relevant.

Chris Davidson

Chris Davidson (KPMG) believes that HMRC has misinterpreted the 2004 DOTAS rules by issuing APNs on the basis that they are substantially the same as a previous transaction that was notifiable under DOTAS.

Thomas Dalby

Thomas Dalby (Gabelle) looks at HMRC’s next move following the closure of the EBT settlement opportunity.

Michael Conlon KC

Julian Hickey

‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter affecting the City.

Santhie Goundar

The High Court has rejected a judicial review application challenging the legality of accelerated payment notices, as well as their compatibility with human rights (Nigel Rowe and others v HMRC [2015] EWHC 2293).

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