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...
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...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
This Q&A considers a UK resident trust.See Practice Note: Trust expenses, which includes a discussion on income expenses and capital expenses.Although...
The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship created by a person, the settlor, when...
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESIndividual trustees v corporate trusteeThe most common trustee structures used...
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESTrustees may be subject to personal liability if they commit a breach of trust...
For general information on Guernsey, see Practice Note: Private Client jurisdictional guide—Guernsey.Guernsey as a trust jurisdictionWhilst there are...
IntroductionMany trusts own shares as part of a portfolio of investments. This Practice Note looks at situations where trustees own shares in order to...
The common law trust has long been a feature in many kinds of commercial arrangements. It has certain unique characteristics which set it apart from...
This Practice Note explains the special stamp duty land tax (SDLT) rules which apply when an interest in land is transferred to a partnership from one...
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