Tax Law

In corporate tax, there’s no hiding. An opinion won’t cut it, unless it’s backed up by authority. And in such a complex, ever-changing area there’s no room for mistakes.

Clear, no-nonsense practice notes take you through what you need to know – with direct links straight to the right part of the trusted tax bibles: Tolley’s Yellow and Orange Tax Handbooks, Simon’s Tax Cases and HMRC’s Manuals. And when you need to delve deeper, direct links to trusted authority, including Simon’s Taxes, Sergeant and Sims on Stamp Taxes, De Voil Indirect Taxes, Tolley’s Tax Annuals, plus articles from Tax Journal and Taxation, in Lexis®Library.

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Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Tax content

Practice notes
This Practice Note discusses a type of UK authorised investment fund called an authorised contractual scheme (ACS). It provides a description of the...
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Produced in partnership with Gordon Gray of KPMG 20th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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20th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.As of 31 January 2020 (exit day), the UK is no longer an EU Member State and its...
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20th Jan
Q&As
For the purposes of this Q&A we have focused on the matters directly relevant to World Trade Organization (WTO) rules as they relate to trade in goods...
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20th Jan
Practice notes
Since A-day (6 April 2006), the main elements of the UK tax regime applicable to employees and other individuals who are members of overseas pension...
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20th Jan
Practice notes
FORTHCOMING CHANGE: At Budget 2020, the government announced that it will conduct a review of the UK funds regime including the VAT treatment of fund...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 20th Jan
Practice notes
FORTHCOMING CHANGE: At Budget 2020, the government announced that it will conduct a review of the UK funds regime including the VAT treatment of fund...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 20th Jan
Practice notes
The loan relationships regime provides the rules for the taxation and relief of a company’s profits and losses from its ‘loan relationships’. The...
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20th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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20th Jan
Practice notes
Coronavirus (COVID-19) and TUPE transfers: the Coronavirus Job Retention Scheme (CJRS), which provides support to employers with a grant to enable...
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20th Jan
Practice notes
This Practice Note is about the extent to which EU law continues to apply to the UK’s tax rules (direct tax and VAT) following the end of the Brexit...
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20th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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20th Jan
Practice notes
A 'non-reporting offshore fund' is any offshore fund which does not have reporting fund status for a particular period of account.For more on what an...
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Produced in partnership with Michael Alliston 20th Jan
Practice notes
Given the ever increasing global mobility of employees, employers could be regularly required to understand and comply with numerous legislative...
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Produced in partnership with Darren Oswick of Simmons & Simmons 20th Jan
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government announced the Coronavirus Job Retention Scheme (CJRS) to support the...
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20th Jan
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on draft...
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20th Jan
Practice notes
STOP PRESS (9/11/20): On 30 October 2020, HMRC published 11 guidance notes giving further details of eligibility for the Job Support Scheme (JSS) and...
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19th Jan
Practice notes
ARCHIVED: This archived Practice Note is not maintained and is for background information only.UPDATE (5/11/20):The Chancellor of the Exchequer, Rishi...
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19th Jan
Practice notes
UPDATE (15/12/20): On 24 November 2020, the Treasury Direction in relation to the third SEISS grant (SEISS 3) was published, and the related HMRC...
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19th Jan
Practice notes
It is common knowledge that value added tax (VAT) is a tax which increases the price of goods and services that consumers in the UK buy. For a tax...
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19th Jan

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