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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Employment taxes content

Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government announced temporary measures to support the employed. For more detail on...
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Produced in partnership with David Smith of DLA Piper 13th Apr
Practice notes
Selecting the right share scheme is fundamental to ensuring that the arrangement meets the company’s specific needs and objectives.This Practice Note...
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12th Apr
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support both the employed and the...
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Produced in partnership with Anne Redston 12th Apr
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support both the employed and the...
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Produced in partnership with Anne Redston 12th Apr
Practice notes
Coronavirus (COVID-19): HMRC has published guidance on how employers should treat certain expenses and benefits provided to employees during the...
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12th Apr
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Off-payroll working (IR35): confirmation of the size of our organisationOn [insert...
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12th Apr
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Status determination statementThis is a status determination statement, provided in...
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12th Apr
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Status disagreement processThis document sets out the process that [insert name of...
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12th Apr
Practice notes
Some payments made on the termination of an employment or office can be paid tax free. Some of these exemptions are often overlooked in practice. The...
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Produced in partnership with Sam Whitaker of Shearman & Sterling 9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 will make the following changes to the off-payroll IR35 legislation:•section 61O of the Income Tax (Earnings and...
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9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 will make the following changes to the off-payroll IR35 legislation:•section 61O of the Income Tax (Earnings and...
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9th Apr
Practice notes
The tax treatment of payments in lieu of notice (PILONs) fundamentally changed under the amendments to sections 402 to 404 of the Income Tax (Earnings...
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Produced in partnership with Sam Whitaker of Shearman & Sterling 9th Apr
Practice notes
Depending on the circumstances, a payment made or other benefit provided in connection with the termination of an office or employment may be taxable...
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Produced in partnership with Sam Whitaker of Shearman & Sterling 9th Apr
Practice notes
Pay as you earn (PAYE) is the mechanism by which income tax (and National Insurance contributions (NICs) and certain other statutory deductions) must...
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9th Apr
Practice notes
Given the ever increasing global mobility of employees, employers could be regularly required to understand and comply with numerous legislative...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes
THIS PRACTICE NOTE RELATES TO REGISTERED PENSION SCHEMESThe lifetime allowanceWhile there is no limit on the total amount of authorised benefits a...
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9th Apr
Practice notes
THIS PRACTICE NOTE APPLIES ONLY TO PENSION SCHEMES IN ENGLAND AND WALESScheme Pays, introduced by Schedule 17 to the Finance Act 2011 (FA 2011) allows...
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Produced in partnership with Herbert Smith Freehills and Naveed Soomro of Squire Patton Boggs 9th Apr
Practice notes
Through the Finance Act 2014, the government introduced two lifetime allowance protection regimes to accompany the reduction in the lifetime allowance...
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9th Apr
Practice notes
There are no limits on the benefits that may be provided by a registered pension scheme. However, under the Finance Act 2004 (FA 2004) if a scheme...
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Produced in partnership with Mark Smith and Georgina Wardrop of Taylor Wessing LLP and Martin Scott of gunnercooke LLP 9th Apr
Practice notes
THIS PRACTICE NOTE RELATES TO REGISTERED PENSION SCHEMESThe lifetime allowanceWhile there is no limit on the total amount of authorised benefits a...
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Produced in partnership with Wyn Derbyshire of gunnercooke LLP 9th Apr

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