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Off-payroll working in the private sector - CIOT comments
  • RPC
  • United Kingdom
  • September 6 2018

In its response to the Treasury and HMRC consultation proposing changes to the off-payroll working rules (IR35) for engagements in the private sector


HMRC publishes Spotlight 44 on the 2019 disguised remuneration loan charge
  • RPC
  • United Kingdom
  • September 6 2018

On 30 July 2018, HMRC published Spotlight 44 on the 2019 disguised remuneration loan charge. The Spotlight reminds taxpayers that if they wish to use


HMRC updates its Company Taxation Manual in relation to the TAAR for close company distributions on a winding up
  • RPC
  • United Kingdom
  • September 6 2018

On 25 July 2018, HMRC updated its Company Taxation Manual in relation to the application of the "main purpose" test (Condition D) in the targeted


Court of Appeal upholds Upper Tribunal decision as to “multifactorial” test for determining “source” of interest
  • RPC
  • United Kingdom
  • August 31 2018

On 21 June 2018, the Court of Appeal upheld the Upper Tribunal's decision in the Ardmore case. In summary, a multifactorial test is to be used when


Court of Appeal denies input tax recovery on supplies mistakenly treated as VAT exempt
  • RPC
  • United Kingdom
  • August 31 2018

On 29 June 2018, the Court of Appeal held that input tax could not be recovered by the recipient of a supply which, originally, was treated as


IR35 - private sector compliance consultation published
  • RPC
  • United Kingdom
  • August 31 2018

On 18 May 2018, HM Treasury published a consultation document exploring proposals to increase 'IR35' compliance in the private sector. The 'IR35'


First-tier Tribunal views outsourced “loan administration” services as standard-rated debt collection
  • RPC
  • United Kingdom
  • August 31 2018

On 20 April 2018, the First-tier Tribunal held that a supply of "loan administration" services to a bank was a standard-rated supply as they amounted


Feeling Blue? Supreme Court reverses Court of Appeal decision - section 75A gave rise to a notional land transaction with consideration of £1.25bn (more than price paid for the land)
  • RPC
  • United Kingdom
  • August 31 2018

On 13 June 2018, the Supreme Court allowed HMRC's appeal in the long-running case regarding the 2007 sale by the MoD of the Chelsea Barracks. Our


Termination payments and post-employment notice pay (PENP) - updated HMRC guidance
  • RPC
  • United Kingdom
  • August 31 2018

On 6 April 2018, HMRC updated its Employment Income Manual to address the changes (taking effect from the same day) to the taxation of termination


Compensation for injury to feelings not taxable as termination payment - Court of Appeal decision
  • RPC
  • United Kingdom
  • August 31 2018

On 20 April 2018, the Court of Appeal held that compensation for injured feelings in connection with a termination of employment fell within the