Personal & employment

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  • Entrepreneurs' Relief: gains before dilution

    Article

    Submitted: 14 March 2018

    The Government proposes to allow individuals, whose shareholding in a trading company is diluted below 5% by an issue of shares to raise funds, to elect to claim Entrepreneurs’ Relief by reference to a deemed disposal of the shares at that time.

  • Employment status consultation: tax aspects

    Article

    Submitted: 09 March 2018

    The Government’s consultation on employment status seeks responses to the way in which the tax system inter-relates with different types of employment status and whether changes should be made to the tax system in that context.

  • Conspicuous unfairness and the Liechtenstein disclosure facility

    Article

    Submitted: 06 March 2018

    HMRC’s 2014 decision to deny further applications to take advantage of the Liechtenstein Disclosure Facility to taxpayers with EBT disputes was not conspicuously unfair.

  • GAAR Panel opinion on contrived employment tax avoidance arrangements

    Article

    Submitted: 05 March 2018

    Arrangements involving an employer financed retirement benefit scheme (EFRBS) which, via a series of tripartite transactions involving deeds of covenants and loans which were later cancelled, resulted in long-term loans to employees were, according to the GAAR Advisory Panel, not a reasonable course of action in relation to the relevant employment tax provisions.

  • Luxembourg publishes list of jurisdictions for CbC reporting purposes

    Article

    Submitted: 02 March 2018

    On 20 February 2018, the Luxembourg government published a regulation listing which countries are to be considered Reportable Jurisdictions under the Luxembourg rules on country by country (CbC) reporting.

  • Taxation of Bitcoin and other similar cryptocurrencies

    Article

    Submitted: 06 February 2018

    An overview of the UK tax treatment of Bitcoin and similar cryptocurrencies.

  • Deductibility of partners' expenses

    Article

    Submitted: 30 January 2018

    The Court of Appeal has confirmed that the trade carried on by a partner in a partnership is the actual trade of the partnership and each partner is not to be regarded as carrying on a separate, distinct trade for the purposes of determining deductible expenditure.

  • Notice to LLP to file partnership return invalid

    Article

    Submitted: 16 January 2018

    The First Tier Tribunal has held that a notice served on an LLP to file a partnership return was invalid, since the UK tax provisions providing for such notices were defective.

  • Redundancy indemnity arrangements and supplies

    Article

    Submitted: 16 January 2018

    Indemnity payments made by a bank to a service provider in relation to the redundancy costs incurred by that provider, as a result of taking on the bank’s former employees, did not amount to consideration for supplies of administration services made by the service provider to the bank.

  • Partnership taxation: proposals to clarify tax treatment

    Article

    Submitted: 14 September 2017

    The Government has released draft legislation for the reform of partnership taxation to be brought into effect from April 2018.

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