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EMPLOYMENT TAXES
Benefits in kind: when are assets ‘made available’?
Liesl Fichardt
Emily Au
It would seem logical that any asset provided by a company to their employees
or directors should be deemed part of their remuneration for tax purposes.
However, the legal position is not always so clear, write Liesl Fichardt and
Emily Au (Quinn Emanuel).
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).
The taxation of off-payroll workers: the legislative waterfall
Penny Simmons
Penny Simmons (Pinsent Masons) considers the interaction of the IR35,
intermediaries and construction industry scheme rules.
Trust issues: examining HMRC’s consultation
Matthew Rowbotham
Many (although not all) of HMRC’s proposals on employee benefit trusts and employee ownership trusts will improve the tax rules, writes Matthew Rowbotham (Lewis Silkin).
20 questions on employee ownership trusts
Nick Wright
Pete Miller
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
The umbrella company consultation: tackling non-compliance
Rebecca Seeley Harris
Rebecca Seeley Harris (Re Legal Consulting) has been campaigning for the regulation of the umbrella company industry and the protection of the worker, under the #FairUmbrella campaign since 2021. Here, she reviews the options for policy change set out in the recent umbrella company consultation.
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.
The taxation of settlement agreements: a new approach?
Joshua Carey
Marianne Tutin
Joshua Carey and Marianne Tutin (Devereux Chambers) discuss a recent tribunal decision that highlights why the tax treatment of sums paid under any settlement agreements must be considered carefully.
Wholly and exclusively: does a tax motive prevent deductibility?
Ross Birkbeck
Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).
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EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
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Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
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Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
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Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
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The VAT treatment of prize draws
The new duty to correct tax return errors
Jury unable to reach verdict in Venables KC tax fraud trial
Home, a loan: the Court of Appeal’s ruling in Elborne
The new Securities Transfer Tax: business as usual?