ITEPA-2003

David Pett

David Pett (Temple Tax Chambers) writes that the FTT in CooperVision has ‘muddied the waters’ and made it more difficult to advise on whether shares are employment-related securities.

Andrew Howard

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine the employment-related securities and valuation lessons from the tribunal’s decision, including the limits of third-party deal pricing and the high bar for protection offered by professional advice.

Dominic Stuttaford

Katharine Wadia

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

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.

Alexander Cox

Loviisa Langdon

Loviisa Langdon and Alexander Cox (Kirkland & Ellis) explain how the new carried interest rules apply to evergreen funds and highlight the complexities surrounding timing, valuation and average holding periods.

Travel expenses taxable as no overarching employment provided by umbrella company

Veronika Lipinska

Matthew Emms

Matthew Emms and Veronika Lipinska (BDO) consider whether, following the 2025 Budget reforms, a CSOP should now revert to EMI, and in what circumstances CSOP or unapproved options might still be relevant.

Class 1A NICs on ‘pooled’ cars: 1993 agreement gives no estoppel or legitimate expectation

UT dismisses IR35 appeal by Sky Sports pundit.

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.

Go to page of 3