Published in 2008

Blackstone’s Employment Law Practice 2008
Oxford University Press

http://www.oup.co.uk/law/series/elps

www.oup.co.uk/law/series/elps

Chapter 25: By Jonathan Schwarz
Tax Treatment of Tribunal Awards and Compromises

“… a useful and succinct chapter on the tax treatment of awards and compromises which I would recommend to all employment lawyers…”
Philip Wood, Dawsons, reviewing an earlier edition the book in ELA Briefing 9 November 2004

This chapter seeks to deal with the tax issues which most frequently arise for employment practitioners as follows:

A. Compensation Packages
B. Taxation of Employment Income
C. Restrictive Covenants
D. Damages for Breach of Contract
E. Termination Payments
F. Termination by Death, Injury, or Disability
G. Redundancy Payments
H. Tax Exempt Pension Schemes
I. Qualifying Counselling Services
J. Legal Fees and Interest
K. Damages for Discrimination
L. PAYE and National Insurance Contributions
M. Application of the ‘Gourley Principle’
N. International Aspects

Published in 2004

Personal Taxation under the European Court of Justice Microscope
Bulletin for International Fiscal Documentation - Volume 58 Number 12 2004
December 2004

Transfer Pricing – The New Regime
TAXline Tax Planning 2004-2005 - Chapter 25
October 2004

2004: A Bumper Year for Treaty Developments?
CCH Tax Treaty Newsletter – Issue 44
January 2004

Unwinding or Otherwise Dealing with “Sandwich” Structures Resulting from an International Merger or Acquisition
With Nathan Boidman and others
Tax Notes International – 10 May 2004

Spin-Offs and Split Offs
With Nathan Boidman and others
Tax Notes International – 13 December 2004

Published in 2003

Capital Gains Under The Spotlight
CCH Tax Treaty Newsletter – Issue 41
September 2003

European Corporate Group Structures and Financing: The Impact of European Court Decisions and European Legislative Development
Bulletin for International Fiscal Documentation - Volume 57 Number 11 2003
November 2003

Permanent Establishments
TAXline Tax Planning 2003-2004 - Chapter 19
October 2003

Stamp Duty Land Tax and Employer Provided Accommodation
TAXline
September 2003 - Issue No.9

Published in 2002

Tax Treaties: United Kingdom Law and Practice
Book published by Sweet & Maxwell
January 2002

Tax Treatment of Tribunal Awards and Compromises
Chapter in Employment Tribunal Practice and Procedure 4^th Edition
published by Sweet & Maxwell

Current European Community Law Issues in Direct Taxation
Chapter in TAXline Tax Planning 2002-2003
2002

European Commission Strategy for Company Taxation in the European Community
Bulletin for International Fiscal Documentation
2002

Intra-Europe Exchange of Direct Tax Information:
The Directive on Mutual Assistance 25 Years On
The EC Tax Journal - Volume 6, 2002 - Issue 1
April 2002
 

Published in 2001

UK Signs Treaty with the US for Exchange of Tax Information Relating to the Cayman Islands
CCH Tax Treaty Newsletter
December 2001

New US Income Tax Treaty
CCH Tax Treaty Newsletter
October 2001

Double Tax Relief Developments
Chapter in TAXline Tax Planning 2001-2002
2001

Attribution of Profits to a Permanent Establishment
CCH Tax Treaty Newsletter
July 2001

Corporate Tax Harmonisation in Europe: A Guide to the Debate - Book Review
British Tax Review - Number 3, 2001
June 2001

Countering Tax Treaty Abuses: A Canadian Perspective on an International Issue - Book Review
British Tax Review - Number 1, 2001
April 2001

The High Cost of Corporate Finance - When Costs are More Complex
Financial Times
30 March 2001

Current Issues under European Community Law on Cross-Border Dividends
Bulletin for International Fiscal Documentation - Volume 55 Number 2 2001
February 2001

Technology Affecting Tax
Business Day - South Africa
8 January 2001
 

Published in 2000

Tax: Focus on E-Commerce
Legal Network Television
22 December 2000 - Issue 337

Era of Universal Company Beckons
Financial Times
17 November 2000

Transfer Pricing - Recent Developments
TAXline Tax Planning 2000-2001 - Chapter 22
October 2000

Greater Scope for Companies now that 'Research and Development' has
Superseded Old Definition of 'Scientific Research'
Financial Times
15 September 2000

Book Review: Practical Guide to US Transfer Pricing by Robert T. Cole
IBFD International Transfer Pricing Journal - Volume 7 Number 3 2000
May/June 2000

E-Commerce Law: Virtual Tax Proves Complex
Financial Times
1 June 2000

Tax and Human Rights
Tax Essentials - Audio Tape by Infosentials
May 2000

Transfer Pricing and E-Commerce
Tax Adviser International Tax Supplement
April 2000

South African Budget Brings Tax Revolution
The Tax Journal - Issue No. 544
17 April 2000

- Transfer Pricing: Stricter Regimes Put Pressure on Boards to Clarify Strategy
- Tax Avoidance: Agreed Definition Proves Elusive
- Tax: Directors' Use of Self-Employed Status May Be At Risk
Financial Times
31 March 2000

Strong Currency Requires A Carefully Charted Course
Financial Times
9 March 2000

Controlled Foreign Companies and E-Commerce: A UK Perspective
Tax Planning International - E-Commerce - Volume 2, Number 3 - 2000
March 2000

Cross-Border Corporate Structures and Financing:
The Impact of European Court Decisions on Tax Discrimination
Bulletin for International Fiscal Documentation - Volume 54 Number 3 2000
March 2000

European Tax Cases
Tax Essentials - Audio Tape by Infosentials
January 2000
 

Published in 1999

Political Paralysis on the EU Tax Front:
- A Divide that is Proving Difficult to Bridge
- European Court Shapes Tax System
Financial Times
10 December 1999

Transfer Pricing and Self-Assessment will Impact on More UK Exporters
Financial Times
9 December 1999

Latest Issues in Transfer Pricing
Tax Essentials - Audio Tape by Infosentials
December 1999

Computer Assisted International Tax Planning for Cross-Border Acquisitions and Mergers
Tax Adviser
October Supplement 1999

Tax and Electronic Commerce: Profound Threat to Revenues
Financial Times
1 October 1999

Transfer Pricing and E-Commerce
Internet Newsletter for Lawyers
September/October 1999

Transfer Pricing and Electronic Commerce
Bulletin for International Fiscal Documentation - Volume 53 Number 7 1999
July 1999

Enforcement of Foreign Revenue Law
The EC Tax Journal - Volume 3, 1999
July 1999

Personal Service Companies: Profiting by International Principles
Financial Times
25 June 1999

What is Tax Avoidance?
TAXline
June 1999 Issue No.6

Current Issues in Transfer Pricing
TAXline Tax Planning 1999-2000 - Chapter 7
June 1999

Attack on Personal Service Companies
IT Lawyer
June 1999

Transfer Pricing: How Far Do The Rules Go?
Taxation
13 May 1999

Multilateral Tax Treaties: Book Review
British Tax Review - Volume 6, 1999
May 1999

What Do The New UK Transfer Pricing Rules Mean?
Bulletin for International Fiscal Documentation - Volume 53 Number 2 1999
February 1999