Tax Talks

The Proskauer Tax Blog

Philip Gilliland

Philip Gilliland

Associate

Philip Gilliland is an associate in the Tax Department.

Prior to joining Proskauer, Philip trained in the London office of a major international law firm where he worked on restructuring and insolvency, corporate M&A and tax matters. During his training contract he undertook a secondment at Unilever.

Philip earned his B.A. from St Catharine’s College, University of Cambridge.

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COVID-19: Taxation of coronavirus support payments

The UK government has opened a consultation on draft legislation concerning the taxation of coronavirus business support payments. HMRC want views on the technical effectiveness of the proposed legislation in ensuring that grants covered by the legislation are subject to tax. Such grants include the much-reported Coronavirus Job Retention Scheme (“CJRS”) (as reported by us … Continue Reading

Advisers’ fees non-deductible where management decisions made by parent company

The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and were charged on to its subsidiary were deductible as expenses of management of the subsidiary under section 1219 of … Continue Reading

IR35 extension to private sector – Finance Bill 2020 amendment on territorial scope

There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain employment status assessment and, depending on the circumstances, employment tax payment obligations from the worker’s … Continue Reading

COVID-19: DAC 6 reporting delayed

In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of taxation. Significantly, the proposal includes an extension to the time limit for reporting information under the new rules on … Continue Reading

COVID-19: interim measures on stamp duty announced by HMRC

In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead an electronic copy (which can be a scanned PDF) should be emailed to HMRC at stampdutymailbox@hmrc.gov.uk. The form … Continue Reading

COVID-19: HMRC Announces its Approach to Company Residence

There has been considerable discussion about the effect that the travel restrictions resulting from the COVID-19 pandemic might have on the tax residence of companies, particularly where directors are stuck in a different jurisdiction and cannot attend board meetings as they would in normal circumstances. On 7 April, HMRC updated its published guidance to discuss … Continue Reading

COVID-19: UK Tax Residence for Companies and Individuals

Introduction In these testing times the ramifications of COVID-19 continue to be felt in every area of personal and corporate life. With lockdowns announced around the world, including in the UK on 23 March 2020, travel has been severely curtailed and business practices are having to change accordingly. Below we discuss what this means for … Continue Reading

COVID-19: UK Chancellor announces measures to support the self-employed

Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key points: The scheme will provide direct cash grants of 80 per cent of individuals’ taxable profits (based on average monthly trading profit … Continue Reading

Coronavirus: UK Chancellor announces unprecedented measures to support the British economy

Earlier this evening the UK Chancellor announced an economic intervention which is “unprecedented in the history of the British state” with measures to support the United Kingdom economy in the midst of COVID-19. Below are the key measures he announced for businesses: The government is setting up a Coronavirus Job Retention Scheme. The scheme will … Continue Reading

UK Budget 2020

The UK Budget took place on 11 March. In its first post-Brexit Budget with substantial spending announcements, the Treasury wants to continue to ensure the UK remains an attractive and competitive place to invest and do business. We have summarized here the most notable tax changes that will be of interest to our corporate and … Continue Reading

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise from avoidance, evasion or repeated insolvency and non-payment of tax debts or tax-related penalties of the company. The legislation is targeted at individuals … Continue Reading

Change to IR35 tax obligations from April 2020 for medium- and large-sized companies

New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to: assessing whether the workers should be treated as employees of the company; and operating employment tax (PAYE and NICs) in respect of payments made to the workers or their intermediary. Currently these obligations rest … Continue Reading
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