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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
Helen Cox
Andrew Goldstone
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
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Rebecca Seeley Harris
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Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
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