Tax analysis: In M R Currell Ltd v HMRC, the Upper Tribunal (UT) considered an appeal of the taxpayer company against a decision of the First-tier Tax Tribunal (FTT) that a director and shareholder of the taxpayer company received taxable earnings in circumstances where the company had made a contribution to an employee benefit trust (EBT) which then subsequently loaned an equivalent amount to the shareholder director. The UT set aside the decision of the FTT and re-made it, allowing the taxpayer company’s appeal.
To continue reading this news article, as well as thousands of others like it, sign in with ÀÏ˾»úÎçÒ¹¸£Àû or register for a free trial
EXISTING USER? SIGN IN CONTINUE READING GET A QUOTE
To read the full news article, register for a free Lexis+ trial
**Trials are provided to all ÀÏ˾»úÎçÒ¹¸£Àû content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. To discuss trialling these ÀÏ˾»úÎçÒ¹¸£Àû services please email customer service via our online form. Free trials are only available to individuals based in the UK, Ireland and selected UK overseas territories and Caribbean countries. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
* denotes a required field
Guidance on making a valid restricted security electionThe procedure for making joint restricted securities elections is the same regardless of whether the election is made under section 425(3), 430 or 431 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). To be valid, an election must
Employment tax implications of a TUPE transferWhen employees are transferred along with the business in which they work pursuant to the Transfer of Undertakings (Protection of Employment) (TUPE) Regulations 2006, SI 2006/246, there will be numerous employment tax implications to consider,
HMRC's powers of PAYE tax recovery from an employeeIn most circumstances, the pay as you earn (PAYE) rules require an employer to deduct tax and employee National Insurance contributions (NICs) from payments to employees, and those amounts may not be recovered directly from the employee. This
Notional payments not made good—the section 222 chargeThe income tax charges associated with employment-related securities and securities options typically arise upon acquisition of securities, or because an amount of employment income is deemed to arise upon a subsequent chargeable event, rather
0330 161 1234