Disguised remuneration and EBTs

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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
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
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 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
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 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
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 Disguised remuneration and EBTs content

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 16th Jan
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 15th Jan
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 15th Jan
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 15th Jan
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 15th Jan
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 15th Jan
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 15th Jan
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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15th Jan
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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15th Jan
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 14th Jan
Practice notes
FORTHCOMING CHANGE: The EU Fifth Anti-Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 11th Jan
Practice notes
FORTHCOMING CHANGE: The EU Fifth Anti-Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force...
Read More >
Produced in partnership with Jeremy Glover of Fenwick Elliott 11th Jan
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 8th Jan
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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6th Jan
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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29th Nov
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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29th Nov

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