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EMPLOYMENT TAXES
Budget 2026: EMI2 - more than an extension of EMI
Louise Jenkins
The Chancellors decision to expand and rename the Company Share Option Plan (CSOP) as EMI2 will be welcomed by businesses seeking to attract and retain talent. The Government positions EMI2 as an option for growing companies that...
Taxing cross-border services: time for a Plan B?
Philip Baker KC
Philip Baker KC (Field Court Tax Chambers) considers why existing rules struggle to tax cross-border services effectively and proposes an alternative solution.
CGT equalisation and share plans: what should remain different?
Nigel Watson
Claire Withers
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.
Employment-related securities: the fallout from Vermilion
David Pett
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.
Legislation Day: draft Finance Bill 2027
A detailed report by Lexis+® UK Tax, with additional practitioner insight.
CooperVision: long-sighted ERS rules
Andrew Howard
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.
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.
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112
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030