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EMPLOYMENT TAXES


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).
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).
Penny Simmons (Pinsent Masons) considers the interaction of the IR35, intermediaries and construction industry scheme rules.
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). 
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
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.
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.
Gary Lineker was successful at the tribunal, while Eamonn Holmes was not. Thomas Wallace (WTT Consulting) explains why.
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.
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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