Tax-free cash meaning

FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, the government confirmed that from April 2029, only the first £2,000 each tax year of a pension contribution made pursuant to a salary sacrifice arrangement will be free of National Insurance contributions (NICs). Any amount sacrificed by an employee above £2,000 a year will attract both employer and employee NICs, so the portion over £2,000 will, for NICs, be handled in line with standard employee workplace pension payments, meaning the excess is treated in the same way as other employee workplace pension contributions for NICs purposes. Employer contributions are unaffected, as is income tax relief. Employers will need to report the total amount of salary sacrificed through existing payroll software, with HMRC committing to engage with stakeholders. HMRC will publish further guidance ‘before April 2029’. The National Insurance Contributions (Employer Pensions Contributions) Bill 2026 will insert a new subsection into section 4 of the Social Security Contributions and Benefits Act 1992 that empowers the government to make regulations providing for...

ARCHIVED: This Checklist has been archived and is not maintained. In broad terms, this computation focuses on real cash movements and payments between the employer and the worker (in both directions) rather than on entitlements. For more detail on the components of this calculation, refer to Practice Note: National minimum wage, especially the section titled: Checking pay against the minimum. For a checklist outlining the key points to consider when deciding whether someone is entitled to receive and does receive the minimum wage, see: Minimum wage compliance checklist...

In this issue: Tax Economic Crime and Corporate Transparency Environmental, social and governance Partnerships Financial services regulation Daily and weekly news alerts Dates for your diary Trackers Useful information Tax HMRC confirms availability of capital-raising exemption from 1.5% stamp duty and SDRT charge. HMRC has updated its Stamp Taxes on Shares Manual (STSM053100) to state that the relief from the 1.5% stamp duty and SDRT for capital-raising covers share issues made for non-cash consideration, with no consideration, or where consideration is paid directly to a different party. See: LNB News 10/04/2024 25. Economic Crime and Corporate Transparency Registrar of Companies and Register of Overseas Entities (Fees) (Amendment) Regulations 2024, SI 2024/454. These Regulations revise the dates on which transitional provisions for changes to Registrar of Companies’ fees apply, correct typographical errors, and remove obsolete references to regulations within the Register of Overseas Entities (Delivery, Protection and Trust Services) Regulations 2022, SI 2022/870. They...

In this issue: Criminal procedure and evidence Proceeds of crime Appeal and judicial review Sentencing Bribery, corruption, sanctions and export controls Cybercrime and data protection offences Environmental offences Financial services and pensions offences Food safety and hygiene offences Fraud, forgery, tax and theft offences Health and safety and corporate manslaughter offences Local authority prosecutions Money laundering International LexTalk®Corporate Crime: a Lexis®Nexis community Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Criminal procedure and evidence Court delays soar as backlogs break records Between April and June 2025, the criminal courts in England and Wales amassed an unprecedented caseload of almost 440,000, with incoming matters exceeding disposals and a system hampered by long-standing funding shortfalls. In response, the Ministry of Justice (MOJ), together with The Rt Hon David Lammy MP, confirmed extra resources to accelerate outcomes for...

UK Care No 1 Ltd v HMRC [2026] UKUT 90 (TCC) The appellant, UKC1, was a Guernsey-incorporated company. It served as the issuer of loan notes within a securitisation structure for the BUPA group. Those notes were placed at a discount and incurred transaction expenses. UKC1 recognised the obligation on an amortised cost basis. That accounting treatment reflected the discounted issue price and the associated fees borne at issue time. (CTA 2009, s 327 is inapplicable where fair value accounting is adopted.) In 2016—when BUPA intended to dispose of certain care homes included in the collateral package—BUPA acquired UKC1 and it became resident for UK tax. UKC1 subsequently bought back the loan notes. The terms for early repayment were set by a ‘Spens’ (or ‘make whole’) provision, which required payment of whichever was greater: the principal sum, or the present value of future cash flows, discounted by reference to a named gilt...

Ordinarily, distributions take the form of cash dividends paid by a company to its shareholders—essentially a straightforward payment of profits to the company’s owners. However, the corporation tax meaning of distribution differs from the company law concept (see Practice Note: Dividends, distributions and scrip dividends). Why does it matter whether a payment is a distribution? It is vital to establish whether a particular payment by a UK company is a distribution because, if it is: the paying company is not permitted a deduction for the amount in its UK corporation tax computation; and a UK corporate recipient will be chargeable to corporation tax on the amount under CTA 2009, Part 9A, unless the payment falls within one of the specific exemptions—for further detail, see Practice Notes: How are small companies taxed on distributions received? and How are non-small companies taxed on distributions received? Since most routine distributions are covered by an exemption from tax, it will usually be in the recipient’s...

Meaning of ‘non-executive director’ The broad definition of ‘director’ is not closed. Under the Companies Act 2006 (CA 2006), a director is any person who occupies the office of director, whatever title they hold. Accordingly, this covers both executive and non-executive directors (NEDs). Executive directors are typically authorised, either by the company’s constitution or by authority delegated from the board, to manage the company’s day-to-day affairs, and they usually have a full-time service contract. NEDs generally: have no executive powers play a pivotal role in the company’s corporate governance are not employees of the company There are a number of challenges around granting shares to NEDs. This Practice Note considers the issues to assess when offering shares or share-based remuneration to NEDs, including: the potential impact on the NED’s independence the share dealing provisions of Assimilated Regulation (EU) 596/2014 for the UK, and the Market Abuse Regulation (Regulation (EU) 596/2014) previously and for the EU ...

THIS PRACTICE NOTE APPLIES TO MONEY PURCHASE ARRANGEMENTS FROM 6 APRIL 2015 From 6 April 2015, new pension flexibilities expanded the retirement choices for DC members and others with ‘flexible benefits’ (in essence, money purchase and/or cash balance entitlements). As part of those reforms, drawdown became more broadly accessible. For background on the changes implemented on 6 April 2015, see Practice Note: Pension freedoms—an introduction [Archived]. This Practice Note concentrates on the legal framework for drawdown arrangements set up on and after 6 April 2015. It also addresses how pre-April 2015 drawdown is treated from that date. For the rules governing drawdown before 6 April 2015, see Practice Note: Drawdown between 6 April 2011 and 5 April 2015 [Archived]. What is drawdown? The label ‘drawdown pension’ (often called ‘flexible income’) replaced ‘unsecured pension’ and ‘alternatively secured pension’ used up to 5 April 2011. Drawdown pension describes the method of paying benefits that allows members to set their own yearly income from a pension arrangement...

We conduct our business [ es ] with integrity. We must all work together to ensure our business [ es ] remain [ s ] free from bribery and corruption. This FAQ, which is central to that aim, sets out how we can achieve our business objectives in a way that aligns with our commitment to combating bribery and corruption. 1 Do the same rules and regulations relating to gifts and hospitality apply in every country? No. Rules and regulations vary from country to country, and in the United States the rules for the federal government are different from those for individual states, and they also differ among the various states. [ Insert organisation’s name ] specifies the appropriate limits for gifts and hospitality in the countries where it operates in our [ international permissible gifts/hospitality limits table ]. 2 A vendor gave me a seasonal gift. May I accept it?...

FORTHCOMING CHANGE: On 26 November 2025, within Budget 2025, the government confirmed that, from April 2029 onwards, only the initial £2,000 per year in total of any pension payment under a salary sacrifice scheme arrangement will escape National Insurance contributions (NICs). Amounts employees sacrifice beyond £2,000 annually will attract both employer and employee NICs, meaning any sum over that limit will, for NICs purposes, be handled in the same way as standard employee workplace pension payments. Employer pension contributions are unchanged, and income tax relief also remains intact. Businesses must record the aggregate salary given up using their existing payroll software systems, and HMRC has pledged to consult and engage stakeholders, as required. Further HMRC guidance will be published ‘before April 2029’...

FORTHCOMING CHANGE On 26 November 2025, as part of Budget 2025, it was confirmed that from April 2029 only the first £2,000 per year of pension contributions made via a salary sacrifice arrangement will be exempt from National Insurance contributions (NICs). Any employee contributions sacrificed above £2,000 a year will attract both employer and employee NICs, meaning the portion exceeding £2,000 will, for NICs purposes, be handled in the same way as other employee workplace pension contributions. Employer contributions are unchanged, and income tax relief remains in place...

Termination payments qualifying for £30,000 exemption As set out in Practice Note: Termination payments qualifying for £30,000 exemption, where a compensation payment for loss of office or employment is made in circumstances where it does not fall to be taxed as: earnings within section 62 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003) (see Practice Note: Termination payments taxed as earnings) benefits-in-kind (see Practice Note: How employment income is taxed—non-cash earnings or benefits) benefits from an employer-financed retirement benefits scheme employment-related securities (see: Employment-related securities—overview) disguised remuneration, where termination payments or benefits are provided by a third party (such as an employee benefit trust) rather than the employer (see: Disguised remuneration and EBTs—overview) restrictive undertakings (see Practice Note: Taxation of payments for restrictive covenants or undertakings) and for terminations for loss of office since 6 April 2018...

When is grossing up required? For guidance on when grossing-up is needed, see Practice Note: Grossing up and partly exempt estates, particularly the section entitled 'When is grossing up required?'. Note that on death, if the residuary estate passes wholly to non-exempt beneficiaries, grossing up does not arise, whether or not any specific legacy is tax-free or chargeable. Where a specific legacy is tax-free, the nominated sum or item is delivered as given and the relevant IHT is paid from the estate in the usual manner; the residuary estate is then calculated. If grossing up applies and the combined amount of all specific gifts (both chargeable and exempt) exceeds the value transferred, i.e. the free estate for IHT, section 37(2) of the Inheritance Tax Act 1984 operates to reduce specific gifts so far as required to bring them down to the value transferred. See: IHTM12086, IHTM12088 and IHTM26180 (which sets out computations where abatement is triggered by grossing up). Further reading: Practice Note:...

Acquisition or appropriation of remainderman's interest Under a life interest trust, the life tenant is entitled to live in the property or take the income it produces. The scenario assumes the life tenant might acquire the remainderman’s interest in the property, thereby converting their position into an absolute interest. In such a case, the remainderman would receive cash in exchange for their reversionary interest. Where the Will trust does not confer an express power on trustees to reallocate or modify beneficial interests, the life tenant and the remainderman may agree a variation pursuant to the rule in Saunders v Vautier, so long as they are both of full age and have capacity. This route is unavailable if any minors or unborn persons have, or may have, an interest under the trust. If there are potential beneficiaries of that kind, an application can be made to the court to approve the arrangement under the Variation of Trusts Act 1958. For further guidance, see: Termination of trusts—overview...