ITEPA-2003

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.

Katharine Wadia

Dominic Stuttaford

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.

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.

Steven Porter

Penny Simmons

Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for large businesses on managing IR35 compliance risks.

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).

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