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Latest Tax News

Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

The following Commercial news provides comprehensive and up to date legal information on Continuing duties after Walsham—limitation and the pitfalls of delay (Equitas v Sande Investments)

Tax weekly highlights—8 April 2021

Tax weekly highlights—8 April 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—8 April 2021

UT reinstates follower notice penalty (HMRC v Comtek)

UT reinstates follower notice penalty (HMRC v Comtek)

The following Private Client news provides comprehensive and up to date legal information on UT reinstates follower notice penalty (HMRC v Comtek)

Tax weekly highlights—1 April 2021

Tax weekly highlights—1 April 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—1 April 2021

Featured Tax content

VAT—triangulation

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Bank levy

Bank levy

FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...

Unilateral relief for foreign tax

Unilateral relief for foreign tax

Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...

Plant and machinery allowances—definition of plant and machinery

Plant and machinery allowances—definition of plant and machinery

Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...

Practice notes

VAT on composite supplies

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

Why have a tax covenant?

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

Capital reduction demergers

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

Section 198 and 199 elections on transactions involving real estate

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

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

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
tag iconIn-house
Practice notes

Schemes of reconstruction defined

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

What is a tax determination?

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

Direct tax treatment of damages and compensation payments

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

VAT treatment of damages and compensation payments

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
tag iconIn-house
Practice notes

Types of lending

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

EIS funds, including approved knowledge-intensive funds

The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes

Property authorised investment funds (PAIFs)—summary

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

Clause—tax gross up—commercial agreements

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

Management buyouts—summary of tax issues for management

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

International movement of capital

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

Tax considerations on a loan agreement—the tax indemnity clause

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 Anti-avoidance content

Practice notes

Accelerated payment notices

The Finance Act 2014 (FA 2014) introduced the concepts of an accelerated payment notice (APN) and a partner payment notice (PPN) to help combat tax...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 9th Apr
Practice notes

Disclosable cross-border tax arrangements—DAC 6

FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...
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9th Apr
tag iconIn-house
Practice notes

Disclosure of tax avoidance schemes—SDLT

This Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to stamp duty land tax (SDLT).The procedural...
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9th Apr
Practice notes

Ramsay and prescriptive statutory language

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
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9th Apr
Practice notes

The general anti-abuse rule (GAAR)

FORTHCOMING CHANGE: With effect from Royal Assent to the Finance Bill 2021 (FB 2021), it is expected that:•HMRC will be able to apply the GAAR to a...
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9th Apr
Practice notes

Ramsay—reality and legal form

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
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9th Apr
Practice notes

Disclosure of tax avoidance schemes—VAT (before 1 January 2018) [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note describes the rules on the disclosure of arrangements for...
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9th Apr
Practice notes

The GAAR advisory panel

The general anti-abuse rule (the GAAR):•counteracts (by the making of adjustments on a just and reasonable basis by HMRC or the taxpayer)•tax...
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9th Apr
Practice notes

Ramsay and composite transactions

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
9th Apr
Practice notes

Disclosure of tax avoidance schemes—income tax, corporation tax, CGT and NICs

This Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to income tax, corporation tax, capital gains tax...
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9th Apr
Practice notes

The GAAR procedure

FORTHCOMING CHANGE: With effect from Royal Assent to the Finance Bill 2021 (FB 2021), it is expected that:•HMRC will be able to apply the GAAR to a...
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9th Apr
Practice notes

Follower notices

FORTHCOMING CHANGE: Finance Act 2021 will, with effect from Royal Assent, reduce the maximum level of a standard follower notice penalty to 30% (down...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 6th Apr
Practice notes

Ramsay in reverse

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
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1st Apr
Practice notes

Ramsay as a guide to statutory construction

Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
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1st Apr
Practice notes

Disclosure of tax avoidance schemes—IHT

FORTHCOMING CHANGE: Finance Bill 2021, published on 11 March 2021, contains a number of measures, taking effect from Royal Assent, to take further...
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26th Mar
Practice notes

Penalties for enablers of defeated tax avoidance schemes

FORTHCOMING CHANGE: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to take further action against those who...
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26th Mar
Practice notes

Promoters of tax avoidance schemes

FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to strengthen the...
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25th Mar
Practice notes

Disclosure of tax avoidance schemes—VAT and other indirect taxes (DASVOIT)

FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 (FB 2021) introduces a new information notice that HMRC may issue to anyone it...
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25th Mar
Practice notes

Disclosure of tax avoidance schemes—procedure

FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 (FB 2021) introduces a new information notice that HMRC may issue to anyone it...
Read More >
25th Mar
Practice notes

Scottish general anti-avoidance rule (Scottish GAAR)

The Scottish general anti-avoidance rule (Scottish GAAR) aims to protect revenue through counteracting tax avoidance arrangements, and is intended to...
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Produced in partnership with Andrew Ford of Barr & Ford Limited 9th Mar
tag iconScottish Law

Popular documents

LEXISNEXIS

Title guarantee and covenants for title

On the disposition of a property (whether by way of conveyance, transfer or charge), the party making the disposition will normally provide a title guarantee which implies standard form covenants for title. A landlord may give a title guarantee when granting a lease, but this is rare in practice.

LEXISNEXIS

Claims for use and occupation, mesne profits, double rent and double value

This Practice Note provides guidance on claims for ‘use and occupation’ or mesne profits, and how and when double rent or double value can be claimed.Claims for use and occupationA claim for use and occupation is possible where there is occupation of land without an express agreement fixing the

LEXISNEXIS

Forum non conveniens—scope and application

This Practice Note considers the doctrine of forum non conveniens, also referred to as the appropriate forum or the proper place for a dispute to be determined. This doctrine is of relevance when determining whether the courts of England and Wales have jurisdiction to hear a dispute and is applied

LEXISNEXIS

The Standard Conditions of Sale (5th edition: 2018 revision)—a guide to the main provisions

The Standard Conditions of Sale (SCS), currently in their 5th edition (2018 revision), are a set of standard conditions which are commonly incorporated into contracts for the sale of residential property. The Standard Commercial Property Conditions (Third Edition—2018 Revision) (SCPC) are used for