PSCs, IR35, MSCs and employment intermediaries

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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
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 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
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 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

Most recent PSCs, IR35, MSCs and employment intermediaries content

Practice notes
Where the managed service company legislation applies, the managed service company (MSC) is treated as making to the worker, and the worker is treated...
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15th Jan
Practice notes
The onshore employment intermediaries legislation broadly applies when an onshore employment intermediary entity is used to facilitate the provision...
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Produced in partnership with Patrick Ford of Squire Patton Boggs 15th Jan
Practice notes
This Practice Note explains the income tax provisions that apply to offshore employment intermediaries, including a summary of the position before and...
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Produced in partnership with Patrick Ford of Squire Patton Boggs 15th Jan
Practice notes
What are managed service companies?Many individual workers supply their services to clients, not directly as a self-employed person, but via an...
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15th Jan
Practice notes
This Practice Note explains the income tax provisions that apply to onshore employment intermediaries, including a summary of the position before and...
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Produced in partnership with Patrick Ford of Squire Patton Boggs 15th Jan
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government announced temporary measures to support the employed. For more detail on...
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Produced in partnership with David Smith of DLA Piper 8th Jan
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support the employed. For more detail...
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5th Jan
Practice notes
FORTHCOMING CHANGE: from 6 April 2021, the off-payroll IR35 regime currently applicable to public authorities will be extended to all medium and large...
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5th Jan
Practice notes
The off-payroll IR35 regime broadly applies where:•from 6 April 2017, a public authority, and•from 6 April 2021, a private sector entity (other than...
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5th Jan
Practice notes
This Practice Note explains the general IR35 regime which applies where an individual worker provides services to an end client through an...
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5th Jan
Practice notes
The anti-avoidance legislation known as the 'intermediaries legislation' or, more commonly, 'IR35' (after the reference number of the HMRC Press...
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5th Jan
Practice notes
The off-payroll IR35 regime broadly applies where:•from 6 April 2017, a public authority, and•from 6 April 2021, a private sector entity (other than...
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5th Jan
Practice notes
This Practice Note explains how the deemed employment payment is calculated for income tax purposes, and the attributable earnings are calculated for...
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5th Jan
Practice notes
The general IR35 regime applies where an individual worker provides services to an end client through an intermediary, such as a personal service...
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5th Jan
Q&As
From 6 April 2017, the IR35 rules changed in relation to engagements where, broadly, the end user is a public authority. For the purposes of the new...
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29th Nov
Q&As
Under proposed section 61N of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), the end client in the relationship must provide a status...
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29th Nov
Q&As
A supply of services is defined in the Value Added Tax Act 1994 (VATA 1994) as 'anything which is not a supply of goods but is done for a...
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29th Nov
Q&As
Finance Bill 2017 (FB 2017) contains a major adjustment to IR35 so that where a public sector body engages a worker through a personal service company...
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29th Nov
Q&As
You may wish to consider the employment status of an individual supplying services through a personal service company (PSC) separately, depending on...
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29th Nov

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