In confirming the First tier Tribunal (FTT) decision in NCL Investments Ltd and Smith & Williamson Corporate Services Limited the Upper Tribunal (UT) made comments that call into question HMRC’s guidance on the application of FRS102 for income tax purposes...
We have become aware of a developing issue regarding the CT deduction on share option exercises, which could mean that some companies have over-claimed this relief. This note only relates to CT and does not impact the income tax treatment...
Background to the historical tax treatment of share scheme costs Prior to 20 March 2013 CTA09 s.1038 excluded from tax deductibility any expenses directly related to the provision of shares, where there was a deduction under CTA 2009 part 12 for...
UK-resident companies employing internationally mobile employees (IMEs) will benefit from changes in the Finance Bill. A corporation tax deduction will be available in relation to an employee of a non-resident employer that is not within the charge to UK corporation tax, if the employee...
Finance Bill 2014 will change the rules taxing employment-related securities (ERS) and employment-related securities options (ERSO) of internationally mobile employees (IMEs). The biggest effect of the change is that income on ERS acquired when non-resident will become taxable as from...
Finance Bill 2014 will change the rules taxing employment-related securities (ERS) and employment-related securities options (ERSO) of internationally mobile employees (IMEs). The biggest effect of the change is that income on ERS acquired when non-resident will become taxable as from...
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