2016-17—Autumn Statement to Finance Bill

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Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

The following Tax news provides comprehensive and up to date legal information on FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

Featured Tax content

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...

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....

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...

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

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...

Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan

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...

9th Nov

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...

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...

9th Nov

In-house

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...

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...

Produced in partnership with Philip Rutherford 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...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

Practice notes

Tax considerations on a loan agreement—the tax gross up clause

It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...

Produced in partnership with Eloise Walker of Pinsent Masons 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...

Produced in partnership with Martin Wilson 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...

9th Nov

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...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan

Practice notes

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...

Produced in partnership with Martin Wilson 12th Jan

Practice notes

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,...

9th Nov

Practice notes

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...

Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan

Practice notes

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,...

Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan

Practice notes

SDLT—deeds of rectification

Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...

9th Nov

Most recent 2016-17—Autumn Statement to Finance Bill content

Practice notes

Finance Act 2017—progress through Parliament [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note contains information on Finance Act 2017 (FA 2017) which...

9th Apr

Practice notes

Autumn Statement 2016 to Finance Bill 2017—Tax Analysis [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note draws together analysis on the key milestones of the 2016-17...

9th Apr

Practice notes

The Budget and Finance Bill process

The Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating to the national economy. This...

9th Apr

Practice notes

Finance (No 2) Act 2017—progress through Parliament [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note contains information on Finance (No 2) Act 2017 (F(No 2)A...

9th Apr

Q&As

When do the changes to the NICs treatment of payments in lieu of notice (PILONs) and termination payments in excess of £30,000 take effect?

First, the extension of the (employee and employer) Class 1 National Insurance contributions (NICs) charge to all PILONs, whether contractual or...

29th Nov

Q&As

When does the extension of the IR35 rules to public sector bodies as set out by the Finance Bill 2017 apply?

Finance Bill 2017 (FB 2017) contains a major adjustment to IR35 so that where a public sector body engages a worker through a personal service company...

29th Nov

2016-17—Autumn Statement to Finance Bill

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Latest Tax News

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

FTT agrees with HMRC’s methodology for calculating output tax assessments (Jupiter Asset Management Group Ltd)

FTT allows unilateral credit for US withholding tax when treaty relief did not apply (Aozora GMAC Investments v HMRC)

Featured Tax content

International movement of capital

Management buyouts—summary of tax issues for management

Clause—tax gross up—commercial agreements

Value shifting

Most recent 2016-17—Autumn Statement to Finance Bill content

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