Related arrangements meaning

Legislation safeguards the pension entitlements of members of occupational pension schemes and other employment‑related benefit arrangements, including workplace personal pension schemes that receive employer contributions, while they are away from work on statutory family leave. Statutory family leave encompasses: maternity leave paternity leave adoption leave parental leave shared parental leave parental bereavement leave carer’s leave Maternity leave Occupational pension schemes are taken to include a maternity equality rule requiring periods when a member is on maternity leave to be treated in the same manner as periods when they are not on maternity leave. This maternity equality rule applies to both paid and unpaid ordinary maternity leave (OML), as well as to paid additional maternity leave (AML). As a result, under this rule, time spent on OML and paid AML in a defined benefit (DB) scheme is recognised as pensionable service...

This Checklist pinpoints the principal provisions commonly found in a trade mark coexistence agreement. It may serve as a prompt for matters to address when preparing, assessing, or negotiating these arrangements. It can be relied upon as a list of points to review at drafting stage, during review, and throughout negotiations and sign-off process. It may equally be tailored as heads of terms to capture core positions whilst a full trade mark coexistence agreement is finalised. For help on doing so, see Precedent: Heads of terms—commercial contracts. For a model coexistence agreement, see Precedent: Trade mark coexistence agreement. For further detail on factors to weigh when drafting a coexistence agreement, see Practice Notes: Trade mark coexistence agreements and Negotiation guide—trade mark coexistence agreement. Checklist Points to consider Further information Notes (if any) (A) Key commercial considerations ☐ Parties Verify which entities will sign the agreement—specify who owns the trade marks (and related rights) and who is exploiting them. Confirm each party’s legal form and...

ARCHIVED: This Practice Note has been archived and is no longer being maintained This tracker summarises the consultation papers issued by the Prudential Regulation Authority (PRA) from 2017 onwards, together with the release of any follow‑on rules and guidance. For material on consultation papers from the Financial Conduct Authority (FCA) and the Financial Services Authority (FSA), see: FCA consultation paper tracker FSA consultation paper tracker Topic area, consultation paper, description, publication date, end of consultation period, and any Policy Statement / Supervisory Statement are recorded. Regulation of insurance 2023 — CP24/23 – Funded reinsurance. This consultation paper outlines proposed expectations for life insurance firms acting as cedants when entering into, or retaining, funded reinsurance arrangements. The PRA’s proposals reflect its assessment that the rising use of funded reinsurance within the UK insurance market presents significant potential risks, including the prospect of unduly concentrated exposures to correlated, credit‑focused counterparties...

Before assessing whether certain aspects of the income tax and National Insurance contributions (NICs) regimes apply, and if an alternative tax treatment can be chosen, it is vital first to identify the existence of a restricted security in the first instance...

LLC Eurochem North-West-2 and another company v Societe Generale S.A. and other companies [2025] EWHC 1938 (Comm) This is a highly important decision for practitioners dealing with international sanctions, as the court delivers a detailed examination of how EU sanctions interface with domestic sanctions authorities in such circumstances. It also provides an in-depth consideration of the notions of ‘ownership’ and ‘control’ for the purpose of sanctions, including where trust arrangements feature, which is not unusual when there is a link to a designated individual. The ruling is likewise of real assistance to those working with performance bonds and related trade finance instruments in the sanctions context. The background facts The relevant parties The dispute stemmed from six on-demand bonds (Bonds) issued in 2021 and 2022 by Société Générale (SocGen) and ING Bank (ING) (the Banks) in favour of EuroChem North-West-2 (EuroChem NW2), a Russian entity. The Bonds were issued under contracts between EuroChem NW2 and Tecnimont S.P.A (Tecnimont), an Italian engineering company, and its Russian affiliate...

In this issue: Employment taxes VAT International Individuals and income tax Taxes management and litigation Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Employment taxes Appeal court rules that loans advanced through a remuneration trust were chargeable as disguised remuneration and that the linked costs were non-deductible (Marlborough DP Limited v HMRC). In Marlborough DP Ltd, the Court of Appeal dismissed the taxpayer’s case and upheld the Upper Tribunal (UT). It found that amounts lent to a director under a remuneration trust fell within the disguised remuneration regime in Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), as they were made in connection with employment. The Court further concluded that the associated payments were not allowable for corporation tax, since they were not incurred wholly and exclusively for the purposes of the company’s trade. See News Analysis: Court of Appeal...

At the High Court, Judge Andrew Henshaw determined that six actions brought by lessors and Ukrainian airlines against their insurers belong in the Ukrainian courts, finding no compelling justification to keep them in London. He concluded that the insurance policies’ exclusive jurisdiction provisions must be observed, holding them binding on the claimants, effective and applicable to every cause of action. He further found no sufficient reasons to permit the proceedings to continue in this jurisdiction. The claimants contended that the leases did not stipulate any governing court or law for the underlying insurance or reinsurance arrangements. The insurers, however, maintained—per the judgment—that the lessors and airlines had the chance to shape the manner in which the aircraft were insured and reinsured, yet did not insist on any forum for disputes. Judge Henshaw additionally held that the clauses remain enforceable even though they do not nominate a particular Ukrainian court. The judge added that, despite the impact of the war with Russia, the Kyiv City commercial...

People with significant control (PSC) regime The architecture of the people with significant control (PSC) regime, which first commenced on 6 April 2016, is contained in Part 21A of the Companies Act 2006 (CA 2006). Its purpose is to tackle worries about the lack of transparency in corporate ownership, where historically the register captured only the legal holder of shares, not always the beneficial owner. By requiring a PSC register, more precise and up‑to‑date details are available about who ultimately owns and directs companies and other bodies, and this information is made public via the central register at Companies House and remains accessible to the public. It assists prospective investors in their decision‑making. It likewise aids law enforcement bodies with money laundering enquiries. LLPs formed under the Limited Liability Partnerships Act 2000 must keep a record of persons with significant control over the LLP under the Limited Liability Partnerships (Register of People with Significant Control) Regulations 2016, SI 2016/340 (the LLP Regulations), as amended by the Information about People...

The UK’s rules on hybrid and other mismatches Since 1 January 2017, the UK’s hybrid and other mismatch rules (described in this Practice Note as the hybrid rules) have been in force, designed to neutralise tax mismatches arising from how a hybrid instrument or hybrid entity is treated for tax. Although the hybrid rules typically apply to cross-border dealings involving two or more jurisdictions, they can also apply to transactions that are entirely UK domestic. They specifically address: deduction/non-inclusion mismatches (D/NI mismatches), i.e. where a payment under a hybrid mismatch arrangement is deductible in the payer jurisdiction for tax purposes but is not included in the taxable income of a payee or a related party investor; and double deduction cases (DD cases), i.e. where a payment under a hybrid mismatch arrangement gives rise to more than one tax deduction. For more detail on the hybrid rules, see Practice Note: Hybrid mismatches—introduction to the rules. For an overview in table form of...

FORTHCOMING CHANGE relating to UK transfer pricing: At Budget 2025, the government confirmed that it intends to move ahead with a new duty on in‑scope multinationals to submit annual information regarding cross‑border related party transactions and dealings for accounting periods starting on or after 1 January 2027. The detailed rules for the new ‘International Controlled Transactions Schedule’ (ICTS) are expected to be formally issued for technical consultation during spring 2026. A consultation on this measure ran from April through to July 2025. See News Analysis: Budget 2025—Tax analysis—International. This Practice Note reviews the UK transfer pricing rules as they apply to chargeable periods (referred to in this Practice Note for ease and convenience as ‘accounting periods’) commencing before 1 January 2026. Note that the Finance Act 2026 introduced a range of reforms to the UK’s transfer pricing regime, most of which apply for accounting periods beginning on or after 1 January 2026, subject to specified transitional provisions. For wider background on transfer pricing, see Practice Notes: Transfer pricing—what is...

Archived: The ability to offer tax-favoured employee shareholder shares or ESS (commonly used in private equity company arrangements) has now been removed In the Autumn Statement 2016, the government confirmed that certain ESS-related tax reliefs would be withdrawn. The changes remove: The income tax and NICs relief applying to the first £2,000 of employee shareholder shares an individual receives The capital gains tax exemption in respect of all, or a portion, of ESS shares The provision ensuring that, when a company purchases employee shareholder shares from an employee shareholder, the consideration is not treated as a distribution in the shareholder’s hands The withdrawal of these reliefs applies to any employer shareholder agreements entered into on or after 1 December 2016. However, an individual who had obtained independent advice about entering an employer shareholder agreement before 23 November 2016 could still complete the agreement before 1 December 2016 and retain the beneficial income and CGT tax advantages...

ORDINARY RESOLUTION [ That approval be given, in accordance with section 198 of the Companies Act 2006, for a quasi-loan in the sum of [ insert amount of quasi-loan ], to be advanced by [ insert name of subsidiary company ] to [ insert name of director ], a director of the Company. OR That the [ guarantee OR security ] to be provided by [ insert name of subsidiary company ] in relation to a quasi-loan of [ insert amount of quasi-loan ] by [ insert name of person who has given or is giving the quasi-loan ] to [ insert name of director ], a director of the Company, be authorised pursuant to section 198 of the Companies Act 2006. OR That the [ insert details of arrangement falling within the definition of ‘related arrangement’ in section 203(1) CA 2006 ] be authorised in accordance with section 203 of the Companies Act 2006. ]...

Ordinary resolution That approval be granted, under section 197 of the Companies Act 2006, for the Company to make a loan of [ insert amount of loan ] to [ insert name of director ], a director of the Company. OR That, in accordance with section 197 of the Companies Act 2006, the Company’s proposed provision of [ guarantee OR security ] in relation to a loan of [ insert amount of loan ] by [ insert name of person who has given or is giving the loan ] to [ insert name of director ], a director of the Company, be approved. OR That the [ insert details of arrangement falling within the definition of ‘related arrangement’ in section 203(1) CA 2006 ] be approved pursuant to section 203 of the Companies Act 2006...

This Q&A proceeds on the basis that intended lowering of the hurdle attached to the growth shares is not one element of a pre‑arranged sequence of steps or a tax avoidance arrangement (for instance, where the plan from the outset was to grant the shares with a high hurdle and later reduce that hurdle to confer a benefit on employees). In that scenario, HMRC might effectively contend that the employment‑related securities rules are not engaged, and that employees are instead taxable to general earnings, by reference to the cases of PA Holdings Ltd v Revenue and Customs Commissioners and UBS AG v Revenue and Customs Commissioners...