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EMPLOYEE-BENEFITS
EOTs: are they still one of the best ways to sell your company to its employees?
Chris Barker
Matthew Emms
The Budget changes may have reduced the appeal of selling a company to an EOT but it remains a tax-efficient option, write Matthew Emms and Chris Barker (BDO).
Other cases that caught our eye: 17 July 2026
Employee benefit trust and IHT: In J McIlhone v HMRC [2026] UKFTT 995 (TC) (2 July), the FTT held that £4m appointed from an EBT to a sub-trust for one of the company’s two employees and his family ceased to qualify for the IHTA...
A D Bly Groundworks and Civil Engineering Ltd and another v HMRC
Provision for future payments under an unfunded retirement benefit scheme not wholly and exclusively for trade purposes.
What’s allowed for car allowances?
Alex Ali Marks
Simon Down
Simon Down and Alex Ali Marks (Deloitte) review the rules for payments for employees using their private car for business journeys in light of a recent Upper Tribunal decision.
Unpaid remuneration: when symmetry breaks down
Aimee Rotherforth
Fehzaan Ismail
Fehzaan Ismail and Aimee Rotherforth (EY) consider how the statutory provisions relating to unpaid cash remuneration may impact ordinary commercial reorganisations.
Tax and the City review for November 2023
Mike Lane
Zoe Andrews
Target Group
,
Vermilion
and changes to HMRC’s guidance on the double tax
treaty passport scheme are among the developments examined by Mike Lane
and Zoe Andrews (Slaughter and May).
NCL Investments: an 11-0 taxpayer victory
Angela Savin
Michael Brady
Angela Savin and Michael Brady (KPMG Law) review the impact of a recent
Supreme Court ruling.
Remuneration trusts: the importance of facts
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in
Marlborough DP Ltd v HMRC
that suggests the shortcomings in HMRC’s general approach following
Rangers
.
Payne: identifying a ‘goods vehicle’
Sarah Black
Sarah Black (11 New Square) reviews the Court of Appeal decision in the latest instalment of the Coca-Cola ‘car or van’ saga.
NCL Investments: upholding the primacy of accounts
Dominic Stuttaford
Susie Brain
Dominic Stuttaford and Susie Brain (Norton Rose Fulbright) examine the Court of Appeal decision.
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of
2
EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
NEWS
Read all
OECD issues Pillar Two review framework and revised GIR
VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
CASES
Read all
J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
Read all
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
MOST READ
Read all
Grand Smile Design Ltd v HMRC
Raising standards without regulating the profession
Consultation tracker
The Executors of Hunt and others v HMRC
HMRC manual changes: 4 September 2026