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ITEPA 2003
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ITEPA 2003
ITEPA-2003
Saunders: new uncertainty for contractual employee incentive arrangements
Peter North
Rob Sharpe
Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal
ruling on the taxation of stock appreciation rights – a decision that introduces
fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.
PD & MJ Ltd v HMRC
UT dismisses IR35 appeal by Sky Sports pundit.
Freebies
David Whiscombe
Benefits received by reason of a person’s employment are taxable.
David Whiscombe wonders whether that extends to certain gifts made
to government ministers.
IR35: spotting and responding to an HMRC enquiry
Steven Porter
Penny Simmons
Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for
large businesses on managing IR35 compliance risks.
More about the Loan Charge
David Pett
Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister
-style obfuscation, writes David Pett (Temple Tax Chambers).
B Niasse v HMRC
Footballer’s agent fees not an
allowable deduction.
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
PD and MJ Ltd (in members' voluntary liquidation) v HMRC
IR35: FTT fails to follow earlier decision on employment status.
Tax on funding family offices
Robert Langston
A family office, however small, needs to be funded on a commercial basis to
avoid adverse tax issues, writes Robert Langston (Saffery).
Benefits in kind: when are assets ‘made available’?
Liesl Fichardt
Emily Au
It would seem logical that any asset provided by a company to their employees
or directors should be deemed part of their remuneration for tax purposes.
However, the legal position is not always so clear, write Liesl Fichardt and
Emily Au (Quinn Emanuel).
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 30 January 2026
Tax bodies back Lords concerns over IHT reforms, including ‘huge’ burden on PRs
Finance Bill 2026 amendments
PAYE changes for employment expenses and gift aid relief
UK-Peru double tax convention
CASES
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Nimbus: The Disability Consultancy Service Ltd v HMRC
Delphi Derivatives Ltd (in liquidation) v HMRC
Other cases that caught our eye: 30 January 2026
HMRC v MedPro Healthcare
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
Transfer Pricing Guidelines for Compliance
A Budget for its times? The Scottish Budget 2026/27
Case watch