VAT: domestic reverse charge for building and construction services

Building contractors and sub-contractors need to be ready for the biggest change in VAT in years. Vaughn Chown and Kevin Hall review the changes below. 1.  Quick overview The changes commence on 1 October 2019. The new reverse charge...

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Are share options always employment related?

The Employment Related Securities (ERS) legislation in Part 7 of Income Tax (Earnings & Pensions) Act 2003 (‘ITEPA 2003’) was described by Lord Walker in Grays Timber Products v HMRC [2010] UKSC 4 as “complex and obscure”, a point that...

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A trivial confusion

When employers provide small unexpected gifts to their employees, those items are only tax-free if they qualify as a trivial benefit. However, there is a lot of confusion about what constitutes as a trivial benefit as there are two cost points, and...

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NCL Investments Case Study: Were the share options deductible?

The Upper Tribunal has found for the taxpayers in a case mainly concerned with the interaction between the accounting and tax rules, which aimed to resolve the question as to whether charges made to a company’s P&L = account under the...

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How is “Issued Share Capital” measured for ER purposes?

In Hunt v HMRC [2019] UKFTT 0210 (TC), the first-tier tribunal, which was heard on 17 January 2019, considered whether Mr Hunt was eligible for of entrepreneurs’ relief (“ER”) on the proceeds from the sale of shares held in Foviance Group...

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