Assignor-friendly—gross-up clause 1 Any sum payable under this [agreement] shall be paid free and clear of any deduction or withholding in respect of any tax whatsoever, save only as may be required by law. If any deduction or withholding is required, the assignee

Licensor-friendly—gross-up clause 1 Any sum payable under this [agreement] shall be paid free and clear of any deduction or withholding in respect of any tax whatsoever, save only as may be required by law. If any deduction or withholding is required, the licensee shall promptly provide the licensor with such certificates or other documents as it can [reasonably] obtain to enable the licensor

A pension scheme approved to operate by HMRC

Tax‑exempt income describes receipts that are not subject to income tax or, in some contexts, corporation tax, either because they fall outside the charge to tax or are expressly relieved from it. Legal practitioners use the term to distinguish such income from taxable income when advising on personal tax, corporate structuring, charities, investment products and cross‑border planning. In the UK (England & Wales, Scotland and Northern Ireland), the concept is reflected in various provisions of the Income Tax Acts and Corporation Tax Acts (for example, exemptions for certain savings income, ISA returns, some foreign income, and charitable exemptions), rather than in a single statutory definition. In Ireland, comparable exemptions are contained in the Taxes Consolidation Act 1997 and related legislation, including exemptions for specified investment income, certain social welfare payments and income of approved charities and pension schemes. Across all these jurisdictions, classification as tax‑exempt income depends on detailed statutory conditions and, in some areas, case law interpretation. Correctly identifying exempt income affects tax liability, reporting obligations, loss relief, means‑tested benefits and the design of tax‑efficient structures and transactions.

The tax-free lump sum paid to a member of a pension scheme when their benefits come into payment.

FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on 'Modernising the distributions framework'. The consultation includes a range of proposals aimed at reducing opportunities for income tax payers to extract value from companies in the form of capital rather than income, including: • preventing the implementation of new holding company structures which facilitate the extraction of value as capital. Currently, the insertion of a new holding company above an existing group holding company results in the shareholders holding ‘good tax capital’ in the new holding company equal to the market value of the old holding company’s shares. A reduction in capital of the new holding company therefore represents a repayment of capital rather than an income distribution. The consultation proposes that share buybacks and other returns of capital ‘reflect a “frozen” amount of capital on the shares in any future holding company at the amount subscribed on the original investment, matching the CGT deferment of the original base cost’ • relaxing the tax conditions to effect a direct or indirect statutory

Taxable income is the amount of a person’s or company’s income on which income tax or corporation tax is actually charged, after taking into account allowable deductions, reliefs and exemptions. In practice, it is the figure arrived at after starting with total or gross income and then applying the relevant statutory rules to remove non-taxable receipts and deduct permitted expenses and reliefs. In the UK, “taxable income” is a shorthand drawn from the Income Tax Acts and Corporation Tax Acts, rather than a single stand‑alone definition. It underpins the calculation of income tax for individuals and partners, and corporation tax for companies, and is central to advising on tax planning, compliance, PAYE, self‑assessment and HMRC enquiries. In Ireland, the Taxes Consolidation Act 1997 performs an equivalent function, with broadly similar usage and effect, though detailed rules on what is deductible, exempt or relieved differ. Across England & Wales, Scotland, Northern Ireland and Ireland, legal and tax practitioners use “taxable income” consistently to mean the statutory tax base on which the applicable tax rates and bands are applied.

A person is a taxable person while he is, or is required to be, registered for the purposes of VAT (Value Added Tax Act 1994, s 3(1)).

A relevant trust in any tax year in which the trustees are liable to pay any of the UK taxes listed in MLR 2017, SI 2017/692, reg 45(14), in relation to the trust's assets or income.

Supply which gives rise to registration or a charge to tax.

The name given to the scrutiny of legal fees by the auditor of court.

Taxation and insolvency There are relatively few specific rules governing the UK taxation of companies that are subject to insolvency procedures. The UK’s basic approach to the taxation of companies in an insolvency process is that the normal tax rules applicable to the particular situation that has arisen should be applied. One of the consequences of this is that different insolvency procedures often give rise to different UK tax treatments and effects, and so the choice of the procedure adopted is not strictly tax-neutral (although, in practice, tax considerations will rarely determine which procedure is used). The insolvency procedures considered here are: • liquidation (both compulsory and voluntary) (also referred to as a ‘winding up’) • administration • administrative receivership and fixed charge/Law of Property Act (LPA) receivership, and • to a lesser extent, company voluntary arrangements (CVAs), schemes of arrangement and restructuring plans It is not uncommon for companies in financial difficulties to be the subject