This Practice Note:

1. •

   outlines the main UK tax provisions that apply where a fixed charge receiver sells assets owned by a company, and

2. •

   answers the important issues that can arise in circumstances where such actions are threatened

This Practice Note considers:

1. •

   the role of a fixed charge receiver

2. •

   the fact that the company in receivership remains liable for tax

3. •

   withholding tax and the receiver

4. •

   the tax deductibility of the receiver’s fees and expenses

5. •

   value added tax (VAT) in relation to a company in receivership

6. •

   issues relevant where the company in receivership is not UK tax resident, and

7. •

   some practical points

In this Practice Note:

1. •

   fixed charge receivers are also referred to as receivers

2. •

   the company whose assets have been charged, and are being sold, is called the company

3. •

   the creditor (or mortgagee) appointing the receiver is called the appointor, and

4. •

   it is assumed that the receiver, company and appointor