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).
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
Tax-favoured share plans are firmly in the spotlight at the moment. Claire Matthews (Taylor Wessing) reminds us how EMI options work and reviews recent changes.
Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
Georgia Hicks (Devereux Chambers) examines two cases which seek to give authoritative guidance on the application of the Ready Mixed Concrete and business on own account tests.
As we await two Court of Appeal decisions, Georgia Hicks (Devereux Chambers) considers what HMRC’s new approach on the ‘business on own account’ test could mean for taxpayers.