Content written by the author of the leading textbook in this area and includes several sector specific Practice Notes. It links directly to Tolley’s Orange Tax Handbook, Tax Journal and key text De Voil.
Excellent practical content for loans, derivatives and debt capital markets. The content links directly to Tolley’s Yellow Tax Handbook, Simon’s Taxes, Tolley annuals, Tax Journal and key text Ghosh Johnson and Miller.
This is an area where many people find themselves a bit at sea. Our content is practical, detailed and covers the major issues in dealing with a tax enquiry or dispute.
When you need to delve deeper, Lexis+® Tax links you to trusted tax texts, including Tolley’s Yellow and Orange Tax Handbooks, Simon’s Taxes, Sergeant and Sims, De Voil, Tax Journal and Taxation.
Tax analysis: In WWM (Harrogate) LLP v HMRC, the First-tier Tax Tribunal (FTT) decided that a partner in an LLP had no goodwill which he could...
Tax analysis: In MyPay Limited v HMRC, the First-tier Tax Tribunal (FTT) dismissed an umbrella company’s appeals against PAYE determinations and NICs...
Tax analysis: In Lifeplus, the First-tier Tax Tribunal (FTT) allowed the taxpayer’s appeal against HMRC’s Schedule 36 information notice which...
Restructuring & Insolvency Analysis: This decision confirms that directors who implement aggressive tax avoidance arrangements for their own benefit...
The Courts and Tribunals Judiciary has published the outcome of the Remote Participation Review, with a suite of new guidance on remote participation...
This tracker displays the status and most recent developments of key tax cases in the UK Upper Tribunal (UT), the Upper Tribunal for Scotland, the...
Various tax incentives are available to individuals investing in unlisted shares and securities such as shares admitted to trading on AIM. AIM is one...
FORTHCOMING CHANGE: This Practice Note reflects the current legislative position, however, note that certain elements may be impacted by the Digital...
When a company that is resident outside the UK starts doing business in the UK, it will want to know whether and to what extent the activities of that...
STOP PRESS: Changes to transfer of assets abroad codeBetween 30 October 2024 and 19 February 2025, the government set out a call for evidence to...
[To be set out on client’s headed notepaper or with client’s logo]Status determination statementThis is a status determination statement, provided in...
[To be set out on client’s headed notepaper or with client’s logo]Off-payroll working (IR35): confirmation of the size of our organisationOn [insert...
This Agreement is made on [insert day and month] 20[insert year]Parties1[Insert name of selling corporate entity] incorporated in [England and Wales...
1Compliance1.1ReturnsThe Company has duly and properly submitted all [material] computations and returns (including all land transaction returns),...
This Agreement is made on [insert day and month] 20[insert year]Parties1[Insert name of selling corporate shareholder] incorporated in [England and...
VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
A contingent, subordinated right to share in the profits of a private equity fund, which acts as an incentive for private equity executives. The holders of carried interest do not start to share in returns until investors have received (broadly) an amount equal to their original investment plus an additional return on their capital. Carried interest is normally expressed as a percentage of the total profits of the fund. The industry norm is 20% with the fund manager therefore receiving 20% of the profits generated by the fund (although this will not always be the case, as some negotiations with investors will result in a lower percentage).
This allows a trader to account for VAT by reference to his profit margin rather than by reference to the consideration for the supply.
A transaction, of whatever description, relating to securities, and includes in particular (1) the purchase, sale or exchange of securities, (2) issuing or securing the issue of new securities, (3) applying or subscribing for new securities, and (4) altering or securing the alteration of the rights attached to securities (Corporation Tax Act 2010 (CTA 2010), s 751).