Earnings and benefits

STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime Finance Act 2025 (FA 2025) which received Royal Assent on 20 March 2025, implements legislation to abolish the remittance basis of taxation and replace it with a residence-based regime, commencing on 6 April 2025. FA 2025 also replaces domicile as the key factor in establishing liability to inheritance tax. Other changes include amendment of the rules determining excluded property status, the abolition of protected settlements status of offshore trusts, and changes to overseas workday relief.

For information on these changes, see: Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26.

An employee can be remunerated in a number of ways, and any type of reward provided in relation to an individual’s employment may result in income tax and National Insurance contributions (NICs) liabilities. Consequently, Pay As You Earn (PAYE) obligations are likely to arise for the employer. The precise nature of the income tax and NICs charge will depend upon the type of remuneration.

Earnings

The

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Latest Tax News

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Tax analysis: In Haworth and others v HMRC, the Court of Appeal dismissed the taxpayers’ appeal, upholding the First-tier Tax Tribunal (FTT) and Upper Tribunal decisions that the place of effective management (POEM) of Mauritian trusts remained in the UK, meaning that HMRC’s assessments for capital gains were therefore effective. POEM may be distinguished from ‘central management and control’ (CMC) and, as a tie-breaker provision in international tax treaties, only one POEM is to be expected.

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Tax weekly highlights—3 July 2025

This week's edition of Tax weekly highlights includes: (1) the Court of Appeal’s decision in Marlborough DP Ltd (concerning a tax avoidance scheme involving contributions to a remuneration trust), (2) News Analyses on previously reported decisions in JPMorgan Chase Bank NA (on the VAT treatment of certain intra-group supplies), Osmond and Allen (on main purpose under the transactions in securities rules) and Dolphin Drilling (on the meaning of ‘incidental to’ in the oil contractor tax rules), and (3) a proactive CIOT submission to HMRC on the non-domicile taxation reforms.