Business structures

Explore the complexities of choosing and structuring business entities to optimise tax efficiency, compliance, and liability protection. Our expert-guided insights help you navigate regulations, advise on suitable frameworks, and strategise for tax planning. Ideal for legal practitioners seeking to provide robust, informed guidance to their business clients.

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Business vehicles Joint ventures and tax Outsourcing Partnerships Tax groupings Trusts in commercial settings

Latest Tax News

UT remits loan relationship accounting appeal concerning the recognition and deductibility of discount back to the FTT (Barclays Bank PLC v HMRC)

UT remits loan relationship accounting appeal concerning the recognition and deductibility of discount back to the FTT (Barclays Bank PLC v HMRC)

Tax analysis: In Barclays Bank PLC v HMRC, the Upper Tribunal (UT) allowed Barclays Bank PLC’s (BBPLC’s) appeal against the decision of the First-tier...

Tax weekly highlights—11 June 2026

Tax weekly highlights—11 June 2026

This week's edition of Tax weekly highlights includes: (1) new guidance on remote hearings in the First-tier Tax Tribunal and the Upper Tribunal (Tax...

FTT supports HMRC denial of goodwill on incorporation of LLP (WWM (Harrogate) LLP v HMRC)

FTT supports HMRC denial of goodwill on incorporation of LLP (WWM (Harrogate) LLP v HMRC)

Tax analysis: In WWM (Harrogate) LLP v HMRC, the First-tier Tax Tribunal (FTT) decided that a partner in an LLP had no goodwill which he could...

FTT rules that umbrella workers’ fixed-period assignments were separate employments, denying travel expense deductions (MyPay Limited v HMRC)

FTT rules that umbrella workers’ fixed-period assignments were separate employments, denying travel expense deductions (MyPay Limited v HMRC)

Tax analysis: In MyPay Limited v HMRC, the First-tier Tax Tribunal (FTT) dismissed an umbrella company’s appeals against PAYE determinations and NICs...

Featured Tax content

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation payments

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)

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 and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the...

Practice notes

Direct tax treatment of damages and compensation payments

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...
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30th May
Practice notes

Residential service charges—VAT implications

Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Commercial service charges—VAT implications

Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Taxation of UK LLPs

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...
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30th May
Practice notes

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
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30th May
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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30th May
Practice notes

The Budget and Finance Bill process

The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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30th May
Practice notes

Tax treatment of reorganisations of share capital

Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
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2nd Jun
Practice notes

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
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30th May
Practice notes

VAT treatment of intermediaries, agents and disbursements

VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
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Produced in partnership with Mark Rowbotham MA FCILT of Portcullis ISC
13th Oct
Practice notes

Taxation of private equity funds—the investors

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...
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Produced in partnership with Emily Clark of Travers Smith
13th Oct
Practice notes

Tax and offshore funds—what is an offshore fund?

Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
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Produced in partnership with Michael Alliston of Norton Rose Fulbright
13th Oct
Practice notes

Partnerships and capital gains

Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
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2nd Jun
Practice notes

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

Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
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Produced in partnership with Eloise Walker of Pinsent Masons
13th Oct
Q&As

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a share structure identical to the target company?

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a...
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2nd Jun
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)UK real estate can be held as an investment through an offshore...
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2nd Jun

Popular documents

Taxation of UK LLPs

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 partnership (ie it is tax transparent). This means that where an LLP carries on a trade, profession or business with a view to a profit, its profits

Taxation of limited partnerships

Taxation of limited partnershipsThis Practice Note considers specific tax provisions relevant only to a limited partnership formed under English law (as opposed to a general partnership, a limited liability partnership (LLP) or a limited partnership formed under Scottish law).Like a general

If a rentcharge is shown as being informally exonerated on title information, does this apply to the

If a rentcharge is shown as being informally exonerated on title information, does this apply to the current registered owner? Or does the informal exoneration only apply to the parties to the document which informally exonerated the rentcharge?This Q&A considers the situation where, at some

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal fees, will that count as a PET against their estate?A disclaimer is the refusal of a gift prior to acceptance. The refusal of the gift must take place before the beneficiary accepts any benefit