Disguised remuneration and EBTs

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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 Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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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
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
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 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
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 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
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 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
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
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 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: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov

Most recent Disguised remuneration and EBTs content

Practice notes
Trustees are generally treated as UK resident if all the trustees are resident in the UK, or:•at least one trustee is resident in the UK•there is a...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 27th Apr
Practice notes
Employee benefit trusts (EBTs) are commonly used to support employees' share schemes and to provide other benefits to employees in the form of...
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Produced in partnership with Karen Cooper of Cooper Cavendish 22nd Apr
Practice notes
What is disguised remuneration?HMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax...
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Produced in partnership with Wyn Derbyshire of gunnercooke LLP 9th Apr
Practice notes
Overview of potential IHT chargesIt is important when establishing or operating an employee benefit trust (EBT) that the potential for Inheritance Tax...
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9th Apr
Practice notes
The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship created by a person, the settlor, when...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 9th Apr
Practice notes
Under the disguised remuneration rules, the value of the 'relevant step' counts as employment income. For the meaning of a relevant step, see Practice...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 9th Apr
Practice notes
IntroductionHMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to income tax and National...
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Produced in partnership with Karen Cooper of Cooper Cavendish 9th Apr
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support the self-employed. For more...
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Produced in partnership with Karen Cooper of Cooper Cavendish 9th Apr
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government announced temporary measures to support the self-employed. For more detail,...
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9th Apr
Practice notes
Sections 554A–554AA of Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) are referred to by HMRC as the ‘gateway’ to the disguised remuneration...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 9th Apr
Practice notes
The disguised remuneration legislation was introduced in 2011 but has been further developed and extended by subsequent Finance Acts. It is intended...
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Produced in partnership with Karen Cooper of Cooper Cavendish 9th Apr
Practice notes
The huge volume of legislation that comprises Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) (the disguised remuneration...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 9th Apr
Practice notes
This Practice Note focuses on the meaning of a 'relevant step'. One of the requirements set out in the 'gateway' to the disguised remuneration rules...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 9th Apr
Practice notes
Disguised remuneration and share schemesHMRC has, for many years, sought to ensure that the rewards gained from employment are properly subject to...
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26th Feb
Q&As
The Finance Act 2018 introduced reporting requirements into the disguised remuneration loan charge provisions (which are contained in Schedule 11 to...
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15th Feb
Q&As
The disguised remuneration rules, contained in Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), broadly charge to tax...
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15th Feb

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