The following Tax practice note provides comprehensive and up to date legal information covering:
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is a clarificatory amendment to the CIR provisions dealing with REITs to reflect the fact that since 6 April 2020 UK property businesses of non-resident companies are within the charge to UK corporation tax rather than income tax. The second ensures that no penalties arise for the late filing of an interest restriction return if there is a reasonable excuse for the failure. For more information, see News Analysis: Draft Finance Bill 2020–21—Tax analysis—Technical amendments to the CIR.
The rules comprising the corporate interest restriction are lengthy and complex. To assist the reader, this Practice Note starts with a background section and a short, high level summary of the rules. This is followed by a guide to some of the key concepts and principles that underpin the rules and a glossary of key definitions. The main operative provisions of the rules are then considered in more detail in the remaining sections of this Practice Note.
The order of contents is as follows:
High-level summary of the rules
Key concepts and principles
Glossary of key definitions
How the interest restriction is calculated and applied
The fixed ratio method of calculating the interest restriction
The group ratio method of calculating the
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Voluntary manslaughterVoluntary manslaughter consists of those killings which would be murder (because the accused has the relevant mental element for murder) but which are reduced to manslaughter because of one of the three special defences (loss of control, diminished responsibility or suicide
What is QOCS?Qualified one-way costs shifting (QOCS) was introduced on 1 April 2013 as part of the Jackson costs reforms following the removal of a claimant’s right to recover additional liabilities from the defendant, ie success fees and after the event (ATE) insurance premiums. The relevant CPR
This Practice Note is an archive of news from the Loan Market Association (LMA) on LMA documentation and related topics. It covers LMA updates from early 2013 to January 2016. For the latest LMA developments since January 2016, see Practice Note: Loan Market Association (LMA)—latest news on
This Practice Note considers claims for damages for breach of statutory duty. For guidance on claims for damages for a negligent breach of duty of care outside a statutory duty, see Practice Notes:•Negligence—when does a duty of care arise?•Negligence—when is the duty of care breached?Breach of
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