The following Tax practice note provides comprehensive and up to date legal information covering:
This Practice Note covers the extent to which interest expenditure is deductible for income tax payers and corporation tax payers investing in UK real estate. The tax treatment of interest payments for dealers in UK real estate is outside the scope of this Practice Note.
A typical real estate investment involves a taxpayer acquiring property with a view to holding it for a relatively prolonged period of time and earning income from renting out the property to tenants. Where, for example, property is acquired for re-development with a view to selling it at a profit, this is likely to amount to trading (or dealing) in real estate rather than investment. For more details, see Practice Note: Dealing in property or property investment?
As a general rule, interest expenditure on debt to finance a UK property business is only deductible (if at all) in computing income profits (ie profits derived from rental income) and is not deductible in computing a capital gain upon disposal of property.
The deductibility of interest payments depends upon the tax profile of the taxpayer invested in UK real estate and, particularly, whether that taxpayer is subject to:
corporation tax, or
Investors in UK property subject to corporation tax are UK tax resident companies, which are subject to UK corporation tax on their income profits and gains (for details of applicable rates of
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This Practice Note provides an introduction to intercreditor agreements and their key provisions. This Practice Note:•explains the purpose of having an intercreditor agreement and when an intercreditor agreement would be used instead of a deed of priority or subordination deed•provides links to
Facilitating the performance of a duty by public officialsFacilitation payments, also known as facilitating or grease payments, are generally small amounts of money paid to public officials or others as a means of ensuring that they perform their duty, whether more promptly or at all. In some
This Practice Note covers the legal framework and regulatory guidance to be considered in determining whether an arrangement constitutes a contract of insurance and the possible consequences of carrying on activities relating to a contract of insurance without the requisite regulatory permissionsThe
LiabilityFalse imprisonment consists of the complete deprivation of liberty without a lawful basis. Claims will in practice be made against a public body that exercises detention powers, usually a local police force, the Secretary of State for the Home Department or the Secretary of State for
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