PSCs, IR35, MSCs and employment intermediaries

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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 Gary Barnett and Martin Shah 27th Oct
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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13th Oct
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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12th Oct
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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28th Sep
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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27th Sep
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 26th Sep
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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26th Sep
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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26th Sep
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 26th Sep
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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25th Sep
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 25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep

Most recent PSCs, IR35, MSCs and employment intermediaries content

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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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26th Sep
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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27th Sep
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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28th Sep
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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28th Sep
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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28th Sep
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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28th Sep
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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28th Sep
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 Sep
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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30th Sep
Practice notes
This Practice Note explains the anti-avoidance legislation that applies where an individual worker provides services to an end client through an...
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30th Sep
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 30th Sep
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...
Read More >
30th Sep
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...
Read More >
30th Sep

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