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O’Brien v HMRC [2026] UKFTT 127 (TC) In RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45, the Supreme Court decided that a liability to income tax on earnings arises where an employee’s pay is directed to another person with the employee’s consent or passive agreement. A host of later rulings have adopted this redirection doctrine; see, for example, Sheth v HMRC [2023] UKFTT 368 (TC). In this matter, the FTT found that the doctrine extended to monies paid into a contractor loan arrangement. Under that arrangement, the taxpayer, a contractor, became an employee of a company in the Isle of Man. The company entered into contracts with, and issued invoices to, the taxpayer’s clients, paying the taxpayer a modest wage and placing the remainder of his remuneration into an EBT. The EBT applied those funds to provide the taxpayer with interest-free loans that were unlikely ever to be repaid. The company deducted income tax and NICs from the wage but...
Loan market and developments Please provide a succinct outline of the current condition of the loan markets in your jurisdiction and any noteworthy recent developments. The US corporate loan market remains a significant pillar of the US economy. While the US loan market has undergone considerable change in recent years, it is still resilient and continues to be one of the most inventive and consequential areas within the US capital markets. Two principal components of the US corporate loan space are broadly syndicated loans (BSL) and private credit transactions. The BSL segment is a key funding source for medium- and large-sized companies, comprising loans where multiple banks and non-bank financial institutions extend finance through a syndicate of lenders. Private credit typically involves lending by non-bank lenders on a bilateral basis or by a small cadre of lenders (often termed ‘club deals’). Both segments have seen strong growth and transformation over the past several years. Broadly Syndicated Loans Although private credit often captures more media focus, syndicated lending...
What are the methods of raising finance? When a corporate entity seeks funding, it must decide whether to borrow from creditors or issue shares on the equity markets. The choice hinges on several factors, including the preferences and requirements of prospective creditors/investors, and the characteristics of the entity raising capital. For a comparison of obtaining funds through debt versus issuing equity, see Practice Note: Debt securities and equity compared. Loans versus debt securities Loans appear in many guises. A straightforward, frequently used facility is an overdraft. In commercial finance, other common options include: Term loans Revolving credit facilities Lending can be provided by a single lender (bilateral) or a group (syndicated or club deals), and may be secured or unsecured. It can support both short-term and long-term requirements. For more detail, see: Types of lending—overview. Debt securities are instruments that create or evidence indebtedness. Typical forms include: Bonds Medium-term notes (MTNs) Commercial paper ...
This Practice Note offers an overview of the Internet Corporation for Assigned Names and Numbers (ICANN) and explores practical routes for safeguarding brands, including through domain and trade mark protection strategies online. An introduction to ICANN ICANN administers the domain name system which, for many years, previously comprised only roughly 20 generic top-level domains (gTLDs) such as .com, .biz and .net. After the launch of ICANN’s New Generic Top Level Domain Name Programme, over 1,200 additional gTLDs were rolled out from late 2013 onwards in all. That cohort featured .xyz, .top, .loan and .club, alongside certain well-known brands, eg .bmw and .hotmail. The new gTLDs are open to general public registration (eg company.inc). As a result, available domain endings expanded by more than 1,200; for instance, ‘amazon’ might be secured as amazon.shop, amazon.books, amazon.music and similar options. Adoption of the various new gTLDs is, overall, rising quickly—in aggregate, more than 37.8 million domain name registrations under the new gTLDs had been recorded by the close of the first...