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 HMRC v BlueCrest Capital Management (UK) LLP, the Supreme Court considered whether the salaried members provisions in Income Tax...
Tax analysis: In Compound Photonics Group Ltd v HMRC, the First-tier Tax Tribunal (FTT) held that the appellant’s VAT group ceased carrying on...
This week's edition of Tax weekly highlights includes: (1) the Supreme Court’s decision in BlueCrest Capital Management (UK) LLP, (2) News Analysis on...
Law360, London: A senior barrister accused of evading almost £2 million in tax was motivated by a 'sense of intellectual superiority' and sought to...
The Supreme Court unanimously dismissed the appeal brought by BlueCrest Capital Management (UK) LLP (Bluecrest), holding that (i) its members met...
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
Pension schemes sometimes make payments to members that are not in accordance with scheme rules or that may breach other tax or legal regulations. As...
Broadly speaking, tax applies to UK registered pension schemes in three different areas:•tax treatment of member and employer contributions (including...
THIS PRACTICE NOTE APPLIES IN RELATION TO OCCUPATIONAL PENSION SCHEMESWhat are additional voluntary contributions? Why distinguish them from other...
[To be printed on headed notepaper of applicant including full contact details]HMRCSDLT Deferment Applications[[insert relevant HMRC address]]United...
1Capital allowances1.1In this clause 1:CAA 2001•means the Capital Allowances Act 2001Plant or Machinery•means those items forming part of the Tenant’s...
1Capital allowances—for use where the Seller has claimed a first-year allowance or pooled qualifying expenditure on plant and machinery fixtures and...
The ScheduleTax Covenant1Definitions and interpretation1.1Notwithstanding clause 1.3 of this Agreement, in the event of any conflict between the...
1Company's tax residence1.1[Insert name of the company] (the Company) is resident in [insert name of the jurisdiction in which the company is intended...
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).
A degrouping charge currently arises where shares in a subsidiary company are sold whilst that company owns a chargeable asset which it acquired by way of an intra-group transfer in the previous six years; where this is the case, the subsidiary leaving the group crystallises a degrouping charge based on the gain that would have arisen had it sold the asset and reacquired it at market value immediately after the original intra-group transfer.
A simplified method of accounting for VAT.