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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
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
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
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
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
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
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 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
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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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 Earnings and benefits content

Practice notes
FORTHCOMING CHANGE: it was revealed in the Queen’s Speech on 14 October 2019 that the government intends to table legislation, the Employment...
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15th Jan
Practice notes
Companies sometimes provide loans to directors or employees as part of the reward package or on specific occasions to help the individual meet...
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15th Jan
Practice notes
In addition to cash earnings, such as wages or salaries, many reward packages include non-cash items, such as the provision of a car, health insurance...
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15th Jan
Practice notes
The residual liability provisions are the back-stop of the benefits code, providing a means of calculating the value of a benefit provided to an...
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15th Jan
Practice notes
The use of malus and clawbackThe concept of withholding or even recovering value from executives if a material adverse event occurs following the...
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Produced in partnership with Nick Hipwell, Sarah Ferguson and Chris Baker of DLA Piper 11th Jan
Practice notes
Restrictive covenants or undertakingsThese are undertakings given by employees during employment or on termination which restrict their conduct or...
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Produced in partnership with Sam Whitaker of Shearman & Sterling 8th Jan
Precedents
[Insert client’s address]Income tax treatment of staff entertainment and gifts to employees and directors1Purpose of this letterThis letter explains...
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Produced in partnership with Victoria Kirsch of Baker McKenzie 8th Jan
Q&As
As a result of measures to slow down the spread of coronavirus (COVID-19), many countries including the UK are in lockdown. For employees, this often...
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Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 8th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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24th Dec
Practice notes
The UK has a comprehensive code for the taxation of employment income. This Practice Note deals with the basic principles of income tax on employment...
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1st Dec
Practice notes
Companies sometimes provide directors or employees with low interest (or interest-free) loans as part of the reward package or on specific occasions...
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29th Nov
Practice notes
Specific rules in the benefits code in ITEPA 2003, Part 3 apply to 'employment-related loans' and, in certain circumstances, impose income tax and...
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29th Nov
Q&As
As a general rule, an employee is subject to income tax in the UK on his general earnings if he is resident in the UK or he is carrying out employment...
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29th Nov
Q&As
Scholarship income is one of many types of income which are exempt from income tax. The exemption to income tax is set out in section 776 of the...
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29th Nov

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