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New legislation to tackle disguised remuneration

28 November 2017 / Andy Wood
Issue: 4626 / Categories: Comment & Analysis

Removing the disguise


  • The contentious nature of recent provisions relating to employment income provided through third parties.
  • Decisions in recent cases dismissed claims that employees should be subject to PAYE and National Insurance on employment benefit trusts.
  • Failure to repay loans by April 2019 will result in a liability.
  • The retrospection principle was acknowledged but not discussed in committee stage.
  • The government’s protocol states that retrospective changes should be ‘wholly exceptional’.
  • Will there be a legal challenge to the latest provisions?

Like many a good read Finance (No 2) Act 2017 which recently received royal assent contains some interesting plotlines. Those so curious to look ( will require genuine stamina and a flask of strong coffee to navigate their way through a document that is...

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