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EMPLOYMENT TAXES


With speculation over the alignment of CGT and income tax rates, Claire Withers and Nigel Watson (Burges Salmon) ask what that would mean for employee equity and which policy choices it would leave unresolved.
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.
A detailed report by Lexis+® UK Tax, with additional practitioner insight.
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.
The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).
Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).
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).
The UK is likely to become more attractive in the short term for overseas employees but less attractive in the medium to long term, Claire Murray and Nisus Larsen (Alvarez & Marsal) explain.
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision, considers the state of the employment status test, and gives guidance for taxpayers.
While the Supreme Court judgment in Vermilion provides clarity on some of the questions raised by the deeming rule, it does not touch on questions raised by a number of other common scenarios, writes Nigel Doran (Macfarlanes).
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