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EBTs
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EBTs
EBTS
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.
Other cases that caught our eye: 15 September 2023
EBTs and penalties for inaccuracies in returns: Delphi Derivatives Ltd v HMRC [2023] UKFTT 722 (TC) (18 August) is the second decision on the Clavis Herald avoidance scheme in recent weeks. The scheme involved an EBT but its structure was...
HMRC’s trust registration service: changes for employee trusts
Graeme Whitfield
Liz Hunter
Liz Hunter and Graeme Whitfield (KPMG) examine the new registration requirements for EBTs and EOTs.
Tax and the City review for June 2020
Mike Lane
Zoe Andrews
Deeming rules, debits, partnerships and pension funds all feature within this month's update, by experts at Slaughter and May.
Directors’ duties and EBT schemes
Matthew Findley
Dominic Stuttaford
The after-effects of the
Rangers
decision are being felt beyond the tax tribunals. Dominic Stuttaford and Matthew Findley (Norton Rose Fulbright) review lessons from two recent cases on directors' duties for unpaid PAYE and NICs relating to unsuccessful EBT schemes.
Inheritance tax and the requirement to correct
Jon Preshaw
Natalie Martin
Jon Preshaw and Natalie Martin (PwC) identify areas of possible risk.
The corporate tax world in 2017
Ashley Greenbank
Ashley Greenbank (Macfarlanes) picks out some highlights in a year of political and economic turmoil.
The practical issues outstanding following Rangers
Karen Cooper
Karen Cooper (Cooper Cavendish) examines the impact of the recent Supreme Court decision on employee benefit trusts, and speculates on HMRC’s approach to similar structures.
Private client briefing for July 2017
Andrew Goldstone
Stuart Adams
Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide the monthly update on the taxation of private clients.
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.
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Spare us the cUTTer
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PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
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Muller: notional companies and real-world transactions
Ashley Greenbank
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Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
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Katharine Wadia
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Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
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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’
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New Advance Tax Certainty Manual
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HMRC update SP 1/2001
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Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
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TP adjustments and VAT: lessons from Stellantis Portugal
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Ask an expert: Dividend planning under the new close company reporting regime