Rebecca has represented and advised Corporate employers and High Net Worth Individuals (HNWIs) on a range of employment tax issues, examples of which include:
Litigation and settlement of EBT structures
Advice in takeover scenarios on shares and share options, including Part 7 and Part 7A of ITEPA
Employee Share Incentive Plans and Company Share Ownership Plans
Procedural matters on PAYE Regulation 72/80 assessments, interaction with the individual’s Self-assessment obligations
CASES
Successful appeal against Income tax assessments on a husband who paid his wife for administrative duties, including the meaning of “payment” for income tax purposes Mr John C Evans v R & C Commissioners [2010] UKFTT 140: Sole counsel for the taxpayer.
Interaction of PAYE regulations and liability of the employee to pay income tax which should have been deducted at source by the employer but was not: Moyes v Revenue & Customs [2014] UKFTT 1030. Sole counsel for the taxpayer.
Income tax scheme (not designed by me) for the payment of bonuses: Aberdeen Asset Management Plc v HMRC [2012] UKUT 43: Junior Counsel for the taxpayer led by Kevin Prosser QC.
Income Tax Self-Assessment return daily penalties: Donaldson v HMRC [2016] EWCA Civ 761 (unled) penalty appeal affecting 600,000 taxpayers.
CONTACT DETAILS
Please contact the clerks at Devereux Chambers on 0207 353 7534 to discuss how Rebecca can help with your requirements or send an e-mail outlining the issues to [email protected] marked for her attention.