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Executive Tax News

29 June 2011

HMRC v Cotter (2011) - Carry-back of relief for losses in employment

The High Court recently heard a test case regarding the correct procedure for claiming employment loss relief which is available to be carried back against income and gains of previous tax years.  The Court held that such a claim must be made in respect of the year in which the loss arises, and may not be included in a taxpayer's return for an earlier year of assessment.

09 May 2011

PAYE coding errors: carte blanche for employers?

In Thomas James Blanche v HMRC (21 February 2011), the First-Tier Tribunal upheld HMRC's decision to relieve an employer of liability for tax which it had incorrectly failed to deduct from an employee's earnings, and instead to impose liability for the shortfall on the employee.  Does this case signal a lenient approach to employers who make errors in calculating PAYE?

09 May 2011

Kieran Anthony Rogers v HMRC (2011) – Income tax on share transfer to employee

The First Tier Tribunal recently considered the correct test to determine whether a transfer of shares to an employee was within the meaning of "emolument" - and consequently chargeable to income tax - under section 19 of the Income Tax Act 1988 (ICTA 1988).

08 February 2011

Norman v Yellow Pages 2010

This judgment (given 9 November 2010) in the Court of Appeal clarifies that it is the employee's responsibility to determine the position with HMRC for tax payable on any taxable elements received under a compromise agreement.   

11 January 2011

Complex bonus arrangements struck down by Tax Tribunal

The First-tier Tax Tribunal recently considered whether a tax avoidance scheme designed to reduce or eliminate tax on bonuses was effective or not.

20 December 2010

Chidi Anthony Oui- Obihara v HMRC [2010]

This recent judgment made in the First-Tier Tribunal highlights to employers the importance of apportioning the component parts of a settlement payment under a compromise agreement, so that there is no confusion as to the tax treatment.