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HMRC v Industria Umbrella Ltd (In liquidation) [2025] UKFTT 494 (TC) HMRC contended that Industria Umbrella promoted contractor loan arrangements intended to allow contractors to obtain the bulk of their gross contract fees as purported loans, with only a modest slice treated as salary processed through PAYE. Under these arrangements, each worker received an employment contract issued at the same time as a loan agreement. The employment terms specified a basic rate roughly aligned with the National Minimum Wage, whilst the loan documentation enabled payment of the balance of the contract value in a form that was not immediately subject to income tax or National Insurance contributions (NICs). The paired documents operated together to channel remuneration as a loan rather than earnings. In substance, the structure was designed to elevate contractors’ net pay to around 80% of the gross contract value by apportioning remuneration in a tax-favoured way. HMRC informed the company that, in the absence of agreement that the arrangements were notifiable under the DOTAS regime, it would...
ARCHIVED : This Practice Note is archived and is no longer maintained. From 1 April 2017, the worldwide debt cap rules were repealed and superseded by the corporate interest restriction (CIR) rules. Accordingly, the worldwide debt cap described here should be treated as relevant only for periods before 1 April 2017, being the date the CIR took effect. For any period straddling that date, the debt cap should be applied to a notional period ending on 31 March 2017. For more on the CIR, which replaces and repeals the debt cap, see Practice Note: Corporate interest restriction. Relief for finance costs of UK-resident companies that are members of large groups may be restricted (ie disallowed) where, broadly, the group’s UK-based net debt exceeds 75% of the group’s gross debt (the gateway test). The debt cap applies to periods of account beginning on or after 1 January 2010. The provisions that bring about the restriction are often termed the worldwide debt cap regime (although it is possible that the regime...
A B C D E F G H I J K L M N O P Q R S T U V W X Y Z This glossary provides helpful (re)insurance and underwriting definitions. For focused guidance on reinsurance terminology, see Practice Note: Reinsurance—essentials. A Accident An unforeseen or unintended event or incident that typically results in damage or injury (physical or financial) to the insured or a third party. Accidental damage Unintended or unexpected harm or damage caused to property or a person. Accidental death benefit Some life insurance policies pay an extra amount, over and above the original sum insured, if the insured dies because of an accident. Act of God (force majeure) An occurrence beyond anyone’s control, such as a natural disaster. Active underwriter The person with primary responsibility and authority to accept insurance and reinsurance risks on behalf of the members of a syndicate in the Lloyd’s market. See also Underwriter. Actuary A qualified professional who...
Introduction The Community Infrastructure Levy (CIL) is a tariff charged on development. Its statutory footing sits in Part 11 of the Planning Act 2008 (PA 2008), which authorises the Secretary of State to make regulations to provide for CIL’s imposition. Those rules were introduced as the Community Infrastructure Levy Regulations 2010 (the CIL Regulations), SI 2010/948. CIL covers both England and Wales, though this Practice Note addresses only the method for calculating CIL in England for any planning permission issued on or after 1 September 2019 (or a liability notice, whenever served, relating to such a permission). For assistance on working out the CIL sum payable in Wales, and in England for a permission granted before 1 September 2019 or a liability notice, whenever served, for such a permission, see Practice Note: Community Infrastructure Levy (CIL)—calculating CIL in Wales. Context No single provision in the CIL Regulations, SI 2010/948 neatly sets out the precise circumstances in which CIL liability is triggered. Nevertheless, this can be inferred from...
Current ratio Date of calculations: [ insert date of calculations ] Formula: Current assets ÷ Current liabilities Calculation: Result: Result from previous month/year: % movement: If the ratio slips under 1.0, the firm lacks sufficient current assets to meet its current liabilities as they become due. Compare this outcome to the previous current ratio result. If the current ratio is declining and nearing 1.0, calculate the other ratios to gain a clearer view of why the firm is running out of money...
Data Source of data Figure £ Current assets — As per the balance sheet — [ insert figure ] Current liabilities — As per the balance sheet — [ insert figure ] Work in progress (WIP) — Shown under Current assets on the balance sheet — [ insert figure ] Debtors — Listed within Current assets on the balance sheet — [ insert figure ] Creditors — Included within Current liabilities on the balance sheet — [ insert figure ] Turnover — Refer to the P&L statement — [ insert figure ] Operating costs (including fee earner/director salaries) — P&L statement — [ insert figure ] Costs of fee earner salaries — P&L statement — [ insert figure ] Gross profit — P&L statement — [ insert figure ] Net profit — P&L statement — [ insert figure ]...
In the employment tribunals Case no: [ Insert case number ] Between: [ insert name of claimant ] — Claimant and [ insert name of respondent ] — Respondent Claimant's schedule of loss 1. Details Net basic weekly pay: £[ insert amount ] Contractual notice period: [ insert number ] [ weeks OR month[s] ] Statutory notice period: [ insert number ] week[s] Claimant’s date of birth: [ insert date ] Period of service: [ insert date ] to [ insert date ] Complete years of continuous service: [ insert number ] year[s] Age at the effective date of termination (EDT): [ insert number ] years Gross weekly wage: £[ insert amount ] Statutory ceiling for a week’s pay at the EDT: £[ insert amount ] ...
Where the claimant trades as a sole proprietor, the assessment of losses is essentially a calculation of net earnings from self-employment, after deducting all overheads, tax, and similar items from their total gross takings for the year...
Net settling a share award Net settling a share award is employed to cut down the quantity of shares a company is required to issue in order to discharge the award. Awards can, in principle, be net settled against both any exercise price due and any tax or National Insurance contributions (NICs) that arise. Key benefits of net settlement include reduced dilution for existing shareholders and the possibility for a company to stretch its headroom under any relevant dilution limits, thereby enabling those limits to accommodate more awards. Net settlement for tax and NICs means the company issues to the award holder a number of shares whose value equals the post‑tax amount they would have retained had they taken the full, gross allocation and sold sufficient shares on‑market to meet the pay as you earn (PAYE) and NICs obligations due at that point in time in practice. The company then settles the PAYE and NICs by remitting a cash payment to HMRC...