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Disguised Remunerationa and the Loan Charge: The taxation of income paid through a third party

Disguised Remunerationa and the Loan Charge: The taxation of income paid through a third party

Author: David Pett
Publisher: Claritax Books
ISBN: 9781912386352
Published In: September 2020
Format: Paperback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

RMB 994.84

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Description
Contents

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This work explains the practical application of a body of tax legislation that was first enacted in 2011, and that has been amended or re-enacted in most subsequent years. This work is aimed squarely at professional advisers.

The legislation has had a devastating impact on many of the more than 50,000 participators in the schemes, who have ended up much worse off than if they had never entered into the scheme in the first place, even though in reality they often had no choice but to do so if they wanted to accept the remunerative work on offer.

Although formally headed "Employment income provided through third parties", the scope is in reality much wider and can give rise to charges to tax and NIC even if no employment income is received by the employee. The charge also extends to close company directors and even to self-employed contractors. The House of Lords described the legislation as "extremely complex and beyond the scope of most business people to decide whether or not it applies to them". This work is aimed squarely at professional advisers and aims to bring clarity to what Keith Gordon describes in the foreword as a clear contender for the worst legislation ever enacted.

Covers:

background to, scope of, and application of the disguised remuneration rules
year-by-year development of the legislation since 2011
calculation of charges on employees and traders
exclusions from those charges
avoiding the traps
background to, and application of, the 2019 loan charge
knock-on effect of that levy

PART 1 – THE DISGUISED REMUNERATION RULES

1. Introduction and background

2. The “main case”

3. Relevant steps

4. The “close companies” case

5. Exclusions from a DR charge

6. Other pension-related exclusions

7. Other exclusions

8. The charge to income tax imposed by the DR rules

9. Death

10. Reliefs against double taxation

11. Disguised trading income of the self-employed