Johan Barros
As seen in:
Tax Journal
Head of Policy @AccountancyEU tweeting mainly tax, occasional memes & SMEs | @TaxCOOP 35 Leaders of the Future | 🇫🇮+🇵🇹+🇧🇪=🇪🇺 | Tweets own/RT ≠endorse
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Derivatives, repos and stock loans: an overview
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Avoiding avoidance
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HMRC update ERS guidance for Vermilion
HMRC have updated guidance in their Employment Related Securities Manual to take into account the Supreme Court’s decision in Vermilion [2023] UKSC 37 on the application of the deeming provision in the ERS rules. In that case the SC held that the deeming provision in ITEPA 2003 s 471(3) created a ‘bright line’ rule with no general purpose-based let out.
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