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HMRC v RALC Consulting: the latest review of IR35
The so-called ‘IR35 rules’ (more strictly, the ‘intermediaries’ legislation’) were announced just over 25 years ago with...
The case of Cooke v HMRC: the problems caused by a rounding error
Entrepreneurs’ relief (now business asset disposal relief) was introduced in the Finance Act 2008 and has survived longe...
Termination of employment: when is a payment tax free?
One of the issues that has regularly featured in the case law concerning employment tax is the taxation of payments rece...
Cash-based businesses: a claim that profits were overstated
Having just passed the 20th anniversary of the first of my monthly case reports and seeing that the official publication...
Taxing discretionary gifts to employees: OOCL UK Branch v HMRC
A payment made by an employer to an employee will usually be subject to tax as employment income and, in the case of a c...
Transfer of assets abroad: the boundaries of the rules
The transfer of assets abroad legislation (variously abbreviated to ToAA and TAA) was first enacted in 1936....
Vermilion Holdings: how a deeming provision works in the context of employment-related securities
The employment-related securities rules caused a lot of controversy when they were first announced in April 2003, just a...
Employee benefit trust arrangement: careless and deliberate conduct
The attempts of employees (typically, directors) to extract funds from their companies in a tax-efficient fashion and th...
Statutory residence test: the exceptional circumstances rule
In the July 2022 issue of Tax Adviser, I wrote about the anonymised First-tier Tribunal decision of A Taxpayer v HMRC [2...
Loss carry back rules: the case of Civic Environmental Systems
When writing this article, I was reminded of my article ‘What a carry back’ in the January 2020 issue of Tax Adviser....