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Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

The following Tax news provides comprehensive and up to date legal information on Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

The following Tax news provides comprehensive and up to date legal information on Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Featured Tax content

Taxation of redundancy payments

Taxation of redundancy paymentsRedundancy is one of five ways in which an employment contract may be terminated unilaterally by an employer where such...

VAT definition

...

Capital allowances on property sales—pre-contract enquiries

Capital allowances on property sales—pre-contract enquiriesThis Practice Note is about capital allowance-related pre-contract enquiries on a property...

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are...

Practice notes

SDLT—deeds of rectification

SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...

19th May

Practice notes

How employment income is taxed—non-cash earnings or benefits

How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...

19th May

Practice notes

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...

Produced in partnership with Ali Kazimi of Hansuke 19th May

Practice notes

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...

19th May

In-house

Practice notes

Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)

Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...

19th May

Practice notes

Corporation tax—connected persons

Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...

19th May

Practice notes

VAT on composite supplies

VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May

Practice notes

Offshore receipts in respect of intangible property (ORIP)

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...

19th May

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

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...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May

In-house

Practice notes

Tax considerations on a loan agreement—the tax gross up clause

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...

Produced in partnership with Eloise Walker of Pinsent Masons 19th May

Precedents

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...

19th May

Practice notes

Taxation of UK LLPs

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...

19th May

Practice notes

Capital reduction demergers

Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...

Produced in partnership with Zoe Feller of Bird & Bird 19th May

Practice notes

R&D capital allowances

R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...

Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May

Practice notes

Transfer of a trade under common ownership

Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...

19th May

Practice notes

SDLT group relief

SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...

19th May

Most recent Internationally mobile employees content

Practice notes

UK employment tax issues for cross-border employment

UK employment tax issues for cross-border employmentGiven the ever increasing global mobility of employees, employers could be regularly required to...

Produced in partnership with Darren Oswick of Simmons & Simmons 30th Jun

Q&As

What are the UK tax implications for a UK employer when it employs a non-UK resident employee who works entirely in another country?

What are the UK tax implications for a UK employer when it employs a non-UK resident employee who works entirely in another country?Generally, an...

23rd Jun

Q&As

Is an employee of a UK employer liable to UK National Insurance contributions if the employee works solely from abroad and is not liable to UK income tax?

Is an employee of a UK employer liable to UK National Insurance contributions if the employee works solely from abroad and is not liable to UK income...

Produced in partnership with Denis Edwards of Normanton Chambers 23rd Jun

Q&As

Coronavirus (COVID-19)—what are the potential tax consequences of working remotely, including cross-border employment tax issues?

Coronavirus (COVID-19)—what are the potential tax consequences of working remotely, including cross-border employment tax issues?As a result of...

Produced in partnership with Laura Allwright of Simmons & Simmons and Darren Oswick of Simmons & Simmons 6th Jun

COVID-19

Q&As

What are the key potential tax and legal implications of having a non-UK director on the board of directors of a UK company?

What are the key potential tax and legal implications of having a non-UK director on the board of directors of a UK company?Before introducing a...

5th Jun

Practice notes

Internationally mobile employees with securities options

Internationally mobile employees with securities optionsIntroductionThis Practice Note discusses the taxation of internationally mobile employees and...

Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 5th Jun

Practice notes

Practical guidance on the taxation of share options for internationally mobile employees

Practical guidance on the taxation of share options for internationally mobile employeesThis Practice Note summarises the taxation of internationally...

Produced in partnership with Lewin Higgins-Green of FTI Consulting 5th Jun

Practice notes

Internationally mobile employees with employment-related securities

Internationally mobile employees with employment-related securitiesIntroductionThis Practice Note discusses the taxation of internationally mobile...

Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 5th Jun

Practice notes

The UK tax treatment of dual contracts [Archived]

The UK tax treatment of dual contracts [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.One of the features of the UK...

Produced in partnership with Darren Oswick of Simmons & Simmons 5th Jun

Practice notes

Internationally mobile employees and securities options (pre-6 April 2015) [Archived]

Internationally mobile employees and securities options (pre-6 April 2015) [Archived]ARCHIVED: This Practice Note has been archived and is not...

5th Jun

Practice notes

The structure of the statutory residence test

The structure of the statutory residence testThe UK’s first formal tax residency test for individuals known as the statutory residence test (SRT) took...

Produced in partnership with Lisa Spearman of Mercer and Hole and Emma Loveday of Wedlake Bell LLP 5th Jun

Practice notes

The statutory residence test—overseas workday relief

The statutory residence test—overseas workday reliefOverseas Workday Relief (OWR) is a relief from UK income tax for certain non-domiciled...

Produced in partnership with Lisa Spearman of Mercer & Hole 5th Jun

Practice notes

Internationally mobile employees and employment-related securities (pre-6 April 2015) [Archived]

Internationally mobile employees and employment-related securities (pre-6 April 2015) [Archived]ARCHIVED: This Practice Note has been archived and is...

5th Jun

Internationally mobile employees

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Latest Tax News

Supreme Court rules in Franked Investment Income litigation (Test Claimants in the FII Group Litigation v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Featured Tax content

Taxation of redundancy payments

VAT definition

Capital allowances on property sales—pre-contract enquiries

Most recent Internationally mobile employees content

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Contract variation

179. List of offences triable either way.

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