Jonathan Fletcher Rogers considers to what extent the Ramsay principle can be applied to tax avoidance schemes involving employee bonuses.
Was a loan to an employee ‘employment related’?
Employee awards of ‘restricted securities’ were effective
Salary sacrifice arrangements did not work
In Essack, the FTT decided that a payment to surrender a share option fell within ITEPA 2003 s 401 because it arose on the termination of employment. This seems at odds with HMRC’s guidance and another tribunal decision, writes Nigel Doran.
HMRC needs to do more to demonstrate that the revenue protection it claims for the IR35 legislation outweighs the costs it imposes, says the House of Lords Select Committee on Personal Service Companies in a recently published report
Amanda Flint considers the relevant measures, including those on share incentives, dual employment contracts, employment intermediaries and pensions
The Association of Taxation Technicians (ATT) has expressed disappointment at the Budget announcement that the collection of class 2 NIC should be brought within the self-assessment system.
The NIC status of payments by an employer to a third party, such as a pension fund or insurance company, for an employee’s benefit has been litigated for over a decade and produced widely divergent judicial opinions. With the Supreme Court judgment in HMRC v Forde and McHugh Ltd, we now at last have clarity, say Dan Pipe and Nigel Doran
PAYE and pilots