Disguised remuneration and EBTs

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Disguised remuneration and EBTs content

Practice notes
Disguised remuneration—structure of the regime and its implications in practiceIntroductionHMRC has, for many years, sought to ensure that the rewards...
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Produced in partnership with Karen Cooper of Cooper Cavendish 6th Sep
Practice notes
Disguised remuneration and the self-employedCoronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary...
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Produced in partnership with Karen Cooper of Cooper Cavendish 6th Sep
Q&As
What are the reporting requirements under the loan charge provisions?The Finance Act 2018 introduced reporting requirements into the disguised...
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16th Aug
Q&As
Which entity is obliged to settle a tax liability that arises under the disguised remuneration loan charge provisions?The disguised remuneration...
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16th Aug
Practice notes
Exclusions from the disguised remuneration rulesThe disguised remuneration legislation was introduced in 2011 but has been further developed and...
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Produced in partnership with Karen Cooper of Cooper Cavendish 15th Aug
Practice notes
Disguised remuneration—the loan chargeCoronavirus (COVID-19): in light of the coronavirus crisis, the government announced temporary measures to...
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15th Aug
Practice notes
Disguised remuneration—the gatewaySections 554A–554AA of Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) are referred to by HMRC as the...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 15th Aug
Practice notes
Disguised remuneration—tax planning environment before rules introducedThe huge volume of legislation that comprises Part 7A of the Income Tax...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 15th Aug
Practice notes
Employee benefit trusts—UK taxation issuesEmployee benefit trusts (EBTs) are commonly used to support employees' share schemes and to provide other...
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Produced in partnership with Karen Cooper of Cooper Cavendish 15th Aug
Practice notes
Disguised remuneration—the relevant stepsThis Practice Note focuses on the meaning of a 'relevant step'. One of the requirements set out in the...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 15th Aug
Practice notes
Disguised remuneration—the tax charge and responsibility for paying taxUnder the disguised remuneration rules, the value of the 'relevant step' counts...
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Produced in partnership with Pete Miller Miller Partnership for Tolley's Tax Digest and Karen Cooper of Cooper Cavendish LLP 15th Aug
Practice notes
Disguised remuneration and pensionsWhat is disguised remuneration?HMRC has, for many years, sought to ensure that the rewards gained from employment...
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Produced in partnership with Wyn Derbyshire of gunnercooke LLP 15th Aug
Practice notes
What is an employee benefit trust?The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship...
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Produced in partnership with Jeremy Glover (Share Schemes) 15th Aug
Practice notes
Employee benefit trusts—on-shore and offshore trusts and tax implicationsTrustees are generally treated as UK resident if all the trustees are...
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Produced in partnership with Jeremy Glover (Share Schemes) 15th Aug
Practice notes
Employee benefit trusts and inheritance tax considerationsOverview of potential IHT chargesIt is important when establishing or operating an employee...
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15th Aug
Practice notes
Examining common disguised remuneration scenarios in share schemesHMRC has, for many years, sought to ensure that the rewards gained from employment...
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15th Aug

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