PSCs, IR35, MSCs and employment intermediaries

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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
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
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
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
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
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
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
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 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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Produced in partnership with Martin Wilson 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
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
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
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 12th Jan
Practice notes
Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent PSCs, IR35, MSCs and employment intermediaries content

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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7th May
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 7th May
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Status disagreement processThis document sets out the process that [insert name of...
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16th Apr
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Status determination statementThis is a status determination statement, provided in...
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16th Apr
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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15th Apr
Precedents
[To be set out on client’s headed notepaper or with client’s logo]Off-payroll working (IR35): confirmation of the size of our organisationOn [insert...
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12th Apr
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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9th Apr
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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9th Apr
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 9th Apr
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 9th Apr
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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9th Apr
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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9th Apr
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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9th Apr
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 9th Apr
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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8th Apr
Q&As
The off-payroll IR35 regime applies to engagements under which:•an individual personally performs (or is obligated to personally perform) services for...
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16th Mar
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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15th Feb
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
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

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