PAYE

Employment-related securities: differential exit proceeds taxable as earnings

Transactions in securities regime: I Oscroft and others v HMRC [2026] UKFTT 251 (TC) (12 February) confirms HMRC’s long-standing view (put beyond doubt by a subsequent amendment to the legislation) that profits available for distribution include...

Upper Tribunal cancels inaccuracy penalties

Judicial review determining tax residency: K (oao R Houldsworth) v HMRC [2025] EWHC 2848 (Admin) (4 November) revisits an issue which many people might have thought had gone away: the extent to which the (former) IR20 booklet can be relied on when...

Interest on overpaid VAT: For most VAT practitioners, the decision in HMRC v Colaingrove Ltd [2025] UKUT 360 (TCC) (21 October) will be of historical interest only as the interest regime for VAT that was at issue here has been completely...

Payments to employees under tax avoidance scheme were taxable earnings despite purported repayment obligation

Operation of PAYE: Fieldworkhub Ltd v HMRC [2025] UKFTT 1097 (TC) (11 September) concerned a company who took on an employee who was also employed (under PAYE) with another employer. HMRC originally issued the new employer with a DO code –...

Expat’s pension escapes tax as link to employment unbroken by fund transfer

HMRC permission to appeal against case management decisions refused

Insolvency consequences of a failed avoidance scheme: C Purkiss v T Kennedy and others [2025] EWCA Civ 268 (14 March) is not a tax case but will be of interest to many tax practitioners because it concerns the insolvency consequences of a failed...

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