The following Tax practice note provides comprehensive and up to date legal information covering:
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?
A foundational principle of the loan relationships regime is that the profits and losses to be brought into account for corporation tax purposes on a company’s loan relationships are calculated by reference to the treatment of those loan relationships in the company's financial statements. For this reason, it is often said that the tax treatment of loan relationships ‘follows the accounts’. For the general rules governing how profits and losses on loan relationships are calculated and brought into account for corporation tax purposes, see Practice Note: Taxation of loan relationships—the main rules.
In certain situations, however, the loan relationships rules require the tax treatment of a company's loan relationships to depart from the accounting measure of profit and loss. One such situation is where a debt falling to be taxed within the loan relationships rules:
becomes impaired, or
is released (in whole
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The principle of transferred maliceIf a person has a malicious intent towards X and, in carrying out that intent, injures Y, he is guilty of an offence. So, if D shoots at A with intent to kill him but kills B by mistake it is murder; the mistake as to the identity of the victim is irrelevant as D
What is a res judicata?A res judicata is a decision given by a judge or tribunal with jurisdiction over the cause of action and the parties, which disposes, with finality, of a matter decided so that it cannot be re-litigated by those bound by the judgment, except on appeal.Final judgments by
There may be times when, rather than assigning the benefit of an agreement to a third party, the original parties wish instead to end their obligations to each other under that agreement and, in effect, recreate it, with the third party stepping into the shoes of one of the original parties. This is
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