The derivative contracts regime represents a comprehensive, self-contained and exclusive regime for the taxation of a company's derivative transactions in the UK. It only...
This Practice Note considers the UK taxation treatment of securitisation companies that fall within the scope of the permanent securitisation regime. It explains: • what...
This Practice Note summarises the main tax issues arising for the UK acquisition group in a private equity-backed buyout. In particular the note: • describes the tax...
This Practice Note outlines the tax issues that should be considered when a company seeks to restructure its external debt obligations. Other Practice Notes in this...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The general rule is that: • the loan relationships regime forms a self-contained, exclusive, regime for the taxation of corporate debt (ie very broadly, a company's...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
The profits and losses arising to a company from its derivative contracts are, like its profits and losses from its loan relationships, generally brought into account for...
What is Shari'ah compliant financing? Shari'ah compliant financing arrangements, also known as Islamic financing arrangements, are designed to comply with Shari'ah or...
When does a tax lawyer get involved in a bond issue? A tax lawyer is often not called upon until: • the company wishing to raise finance has already decided to raise...
This Practice Note sets out a selection of key resources from Lexis®PSL Tax which may be helpful to banking lawyers and their clients. The links provided in this Practice...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing. This Practice Note...
A secondary buyout (SBO) is broadly where a private equity firm buys a business that has previously been subject to a buyout. This Practice Note examines the tax issues...
This Practice Note: • explains: ◦ the purpose of the tax credit clause that is normally found in a loan agreement, and ◦ that the standard drafting of the tax credit...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to: • prohibit a borrower from deducting (or...
This Practice Note: • explains: ◦ the purpose of the tax indemnity clause that is normally found in a loan agreement, and ◦ that the standard drafting of the clause is...
A company's loan capital is, broadly, money that it has borrowed. It represents the company's debt. What is debt? Loan capital (debt) can, broadly, be compared and...
When the murabaha structure was being developed for use in the UK, practitioners understood that the structure's novelty would produce a degree of uncertainty. As a...
The Hiring Incentives to Restore Employment Act (the HIRE Act) include provisions that give the US Internal Revenue Service (the IRS) administrative tools to: • detect,...
BREXIT: This document contains guidance on subjects impacted by the UK’s withdrawal from the EU including: • on 1 March 2019 the Value Added Tax (Input Tax) (Specified...
This Practice Note: • explains what a whole business securitisation is—a whole business securitisation may also be referred to as an operating asset securitisation •...
In many jurisdictions, including the United Kingdom, borrowers are, in certain circumstances, obliged to withhold a proportion of the interest payable to the lender and...