Georgia Hicks

Oct 17, 2024 | taxjournal.com | Andrew Marr |Chris Etherington |Johan Barros |Georgia Hicks

HMRC have updated guidance in their Employment Related Securities Manual to take into account the Supreme Court’s decision in Vermilion [2023] UKSC 37 on the application of the deeming provision in the ERS rules. In that case the SC held that the deeming provision in ITEPA 2003 s 471(3) created a ‘bright line’ rule with no general purpose-based let out.

Oct 16, 2024 | taxjournal.com | Andrew Marr |Chris Etherington |Johan Barros |Georgia Hicks

In The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Numbers 1 to 4 and another v HMRC [2024] UKUT 319 (TCC) (8 October) the Upper Tribunal (UT) considered two joined appeals against decisions of the First-tier Tribunal (FTT) that exit taxes imposed on trustees of a settlement and a company as a result of ceasing to be UK resident for tax purposes ought not to be disapplied.

Oct 16, 2024 | taxjournal.com | Edward Reed |Clare Wilson |Georgia Hicks

As readers will know equity investors must meet certain prescribed conditions to obtain relief under the Enterprise Investment Scheme (‘EIS’). This includes the need to invest in a company that is carrying out a qualifying trade or will do so within two years of the investment; this was the issue in dispute in Putney Power Ltd and another v HMRC [2024] UKFTT 870 (TC).

Oct 15, 2024 | taxjournal.com | Andrew Marr |Chris Etherington |Johan Barros |Georgia Hicks

Two new Regulations set out conditions for the enhanced rate of AVEC and the date from which applications for low-budget certificates can be made. The Corporation Tax (Certification as Low-Budget Film) Regulations SI 2024/1009 set out the budget condition and creative connection condition and the necessary supporting evidence for those conditions for the purposes of the enhanced audio visual expenditure credit (AVEC).

Oct 15, 2024 | taxjournal.com | Andrew Marr |Chris Etherington |Johan Barros |Georgia Hicks

Published on 10 October 2024 the Employment Rights Bill sets out various protections for workers including restricting zero-hours contracts and extending some existing employment rights from day one of employment and makes various changes to the industrial relations landscape.