Tax Aware

Tax Aware

Issue 9
7311Tax and tax alike: Tax disposals of UK property reduced for certain companies and balanced for non-residents

Tax and tax alike: Tax on disposals of UK property reduced for certain companies and balanced for non-residents

On 6 April 2019, HMRC introduced rules that seek to tax non-residents on disposals of UK residential and commercial property in the same way as their UK-resident counterparts. This follows the government consultation that closed in February 2018.

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7314Facts trump the deeming provision in Vermillion: Share options granted to directors are not always taxed as employment-related securities

Facts trump the deeming provision in Vermillion: Share options granted to directors are not always taxed as employment-related securities

When employees or directors (or persons who become employees or directors), receive shares or options, HMRC's starting point is to deem the securities have been received by virtue of the employment or directorship.

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7316Safeguards given "Teeth" for taxpayers and HMRC alike: Conditions for discovery assessments clarified

Safeguards given "Teeth" for taxpayers and HMRC alike: Conditions for discovery assessments clarified

In HMRC v Tooth [2019] EWCA Civ 826, the Court of Appeal clarified the conditions necessary for HMRC to raise conduct-based 'discovery' assessments.

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7318Balancing salary sacrifice with the national minimum wage: Naming and shaming scheme under review

Balancing salary sacrifice with the national minimum wage: Naming and shaming scheme under review

The government recently announced that its 'Naming and Shaming' scheme in relation to the National Minimum Wage (NMW) is under review.

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7320Parry: Inheritance tax risks for transfers between pensions schemes

Parry: Inheritance tax risks for transfers between pensions schemes

In HMRC v Parry & Ors [2018] EWCA Civ 2266, six weeks before her death and when in ill health, Mrs Staveley transferred pension benefits from one pension scheme to another.

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7322IR35 changes: Risks to be transferred to private sector clients

IR35 changes: Extension to the private sector for provision of services via intermediaries

From 6 April 2020, IR35 risks will transfer to private sector clients who engage the services of individuals (such as freelancers, contractors or consultants) through an intermediary.

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