Tax dispute resolution
With HMRC receiving more information than ever, and with increasing pressure on public revenues, HMRC are expected to use the full extent of its investigatory powers to actively reduce the tax gap.
The legislation is complex and there is every likelihood it will impact the timing of tax and NIC liability in unexpected circumstances. There are exceptions made for both UK pension schemes and HMRC approved share schemes, but the legislation could adversely affect for example unapproved employee share plans, deferred cash bonus plans and non-UK pension schemes. The likelihood is that any post-8 December receipt from these arrangements will be taxed as income. However much depends on the detail of individual circumstances and it is particularly important that advice is taken on all remuneration strategies - even those not intended to use tax avoidance structures. We are working with our clients to evaluate the implications. If you have any concerns please contact our tax investigations and employer solutions team.
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