Employment Tax
We advise clients across diverse sectors on a wide variety of employment tax issues, and have a co-ordinated team of lawyers across our UK offices with responsibility for broadening and strengthening our employment tax offering.
Employment tax issues are wide-ranging and the following are just a handful of examples of areas in which we can help:-
- Employment status issues and disputes.
- Internationally mobile employees.
- Termination of employment, redundancy and payments in lieu of notice.
- Employment related securities issues and planning (see also Employee Share Plans and Entrepreneur Tax Planning).
- The tax treatment of benefits and expenses.
- Cost savings through benefits planning, including salary sacrifice, pensions tax, alternative investment structures (e.g. EFRBS) and use of corporate medical benefit trusts.
Recent experience
- Acting for UBS AG in the First Tier Tax Tribunal in UBS AG v HMRC [2010] UK FTT 648(TC) concerning its employee incentive arrangements.
- Advising a fully listed company on its overall remuneration package in the light of the 50% tax rate.
- Advising a fully listed company on changing from conventional private health insurance to the use of a corporate medical benefit trust.
- Advising a large offshore multinational on the tax issues arising from duties performed by its CEO in the UK, where the CEO also lived and worked in a large number of other jurisdictions. Advice included the CEO's liability to UK income tax and national insurance contributions and the employer's potential liabilities given the apparent lack of a permanent establishment in the UK.
- Advising a government department on a challenge by HMRC to the employment status of its contractors, resulting in HMRC's withdrawal of claim for a minimum of £5 million (plus interest and penalties).
- Carrying out an employment status audit for a major company in respect of a newly acquired business, and advising on the restructuring of working practices to manage the risks.
- Advice to a consultancy firm specialising in executive relocations, on the issues arising from working for short periods in the UK and providing advice to their underlying clients on all aspects of UK taxation for non UK domiciled, non UK resident individuals working on both short and medium term UK contracts.
- Advising a large company on a HMRC enquiry into its termination payments, and successfully defending them against a threatened tax assessment.
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