Tax analysis: In Bryan Robson Limited v HMRC the First-tier Tax Tribunal (FTT) allowed in part the taxpayer company’s appeal against PAYE determinations and NIC decisions under the intermediaries’ legislation (IR35). The FTT held that the legislation applied to the company’s 2019 contract with Manchester United except to the extent that it related to image rights. The decision is in principle only; the FTT left the parties to agree the figures
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Corporation tax relief for employee share and share option acquisitionsAn employing company is entitled to corporation tax relief, under a specific set of rules in the Corporation Tax Act 2009 (CTA 2009), in relation to:•the acquisition of shares (including on exercise of a share option)•by an
HMRC's powers of PAYE tax recovery from an employeeIn most circumstances, the pay as you earn (PAYE) rules require an employer to deduct tax and employee National Insurance contributions (NICs) from payments to employees, and those amounts may not be recovered directly from the employee. This
Convertible securities—tax treatmentThis Practice Note explains the income tax treatment of convertible securities. The definition of convertible securities is set out in Practice Note: Convertible securities—definition.The basic effect of the rules applying to convertible securities (or an interest
Tax analysis: In Atholl House Productions Ltd v HMRC, the First-tier Tax Tribunal (FTT) upheld the taxpayer’s appeal, holding that the intermediaries legislation (or IR35) did not apply to arrangements entered into between the taxpayer and the BBC in relation to the provision by the taxpayer of the
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