
Articles
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Oct 23, 2024 |
taxjournal.com | Matthew Mortimer |Andrew Marr |Chris Etherington |Johan Barros
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Oct 18, 2024 |
taxjournal.com | Graham Webber |Andrew Marr |Chris Etherington |Johan Barros
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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.
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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.
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Oct 16, 2024 |
taxjournal.com | Oliver Marre |Andrew Marr |Chris Etherington |Johan Barros
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