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EMPLOYMENT TAXES
The UK’s tax certainty problem
Jenny Batchelor
Ahmed Mobasshir
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).
Employment status in regulated sectors: key takeaways from PGMOL
Amelia Roffey
Henry Bennett-Gough
Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).
EOTs: are they still one of the best ways to sell your company to its employees?
Chris Barker
Matthew Emms
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 Foreign Income and Gains regime: employer considerations
Nisus Larsen
Claire Murray
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.
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The ERS deeming rule: clarity from the Supreme Court
Nigel Doran
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).
What should be done about carried interest?
Heather Self
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).
EMI takes its turn in the spotlight
Claire Matthews
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.
IR35: two media cases with different outcomes
Tom Wallace
Gary Lineker was successful at the tribunal, while Eamonn Holmes was not.
Thomas Wallace (WTT Consulting) explains why.
Murphy: earnings and settlement agreements
Sam Way
Joshua Carey
The Court of Appeal’s decision brings refreshed simplicity to a tortured area of the law, write Joshua Carey and Sam Way (Devereux Chambers).
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem