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Commentary

E4.1219B Remuneration packages and tax avoidance factors

Personal and employment tax

E4.1219B Remuneration packages and tax avoidance factors

General tax avoidance factors and employment reward

In using this material to plan an employment package that is cost-effective, it is suggested that first, the specific tax and National Insurance legislation that applies to special categories of employee and special employee situations should be considered (for example, agency workers and employees working away from their home country). Then, in relation to more general employment situations, the component parts of the contract can be identified and the tax and NICs savings opportunities for both the employer and the employee maximised, by ensuring that wherever possible the earnings qualify for any special reliefs from both tax and National Insurance contributions that are available.

In all planning associated with employment income, the application of the Ramsay principle (of fiscal nullity being ineffective) in the PAYE case of DTE Financial

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