The following Tax practice note Produced in partnership with Charles Goddard of Rosetta Tax provides comprehensive and up to date legal information covering:
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This Practice Note covers the anti-avoidance measure for transactions in land which was designed to charge gains of a capital nature arising from the disposal of land to income tax or corporation tax on income. These provisions were introduced in 1969 and were found in sections 815–833 of Corporation Tax Act 2010 (for corporation tax) and sections 752–778 of Income Tax Act 2007 (for income tax). The anti-avoidance measure examined in this Practice Note was replaced and extended by the offshore property developer rules which were introduced with effect from 5 July 2016. For more details of these rules, see Practice Note: Profits from trading in and developing UK land (transactions in UK land). The provisions of CTA 2010, ss 815–833 (for corporation tax) and ITA 2007, ss 752–778 (for income tax) no longer apply with effect from 5 July 2016.
HMRC can also use a range of other measures to counter income tax, corporation tax, stamp duty land tax (SDLT) and VAT avoidance in relation to land, not least the general anti-abuse rule (GAAR) (for further details, see our GAAR subtopic).
For further details of such measures in the context of income tax and corporation tax, see Practice Note: Real estate—anti-avoidance: sale and leasebacks, taxing lease receipts as income and general anti-avoidance rules. See also
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This Practice Note discusses Term Loan B (TLB) facilities which frequently appear as a tranche of senior facilities in syndicated loans in leveraged financings. TLBs are an established feature in the US market and increasingly used in the European lending market for institutional investors.This
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Background to the Single RulebookHistorically, the European Commission (Commission) favours using Directives (rather than Regulations) to set out its legislation in respect of the financial services sector. However, Directives, allowing Member States greater flexibility in how they implement
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