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

High Court sanctions Part 26A restructuring plan despite HMRC’s opposition and valuable tax losses (Re Waldorf)

High Court sanctions Part 26A restructuring plan despite HMRC’s opposition and valuable tax losses (Re Waldorf)

Tax analysis: In Re Waldorf, the High Court sanctioned (ie approved) the company’s restructuring plan under Part 26A of the Companies Act 2006,...

Tax weekly highlights—21 May 2026

Tax weekly highlights—21 May 2026

This week's edition of Tax weekly highlights includes: (1) a new online tool and updated guidance on mandatory registration of tax advisers, (2)...

Taxpayer avoids late payment penalties on reallocation of earlier tax payments (Herrmann v HMRC)

Taxpayer avoids late payment penalties on reallocation of earlier tax payments (Herrmann v HMRC)

Tax analysis: In Herrmann v HMRC, the First-Tier Tax Tribunal (FTT) allowed the taxpayer’s appeal against late payment penalties and surcharges,...

FTT allowed film partnership tax deductions where payments were equity-funded but not debt-funded (Take 3.9 TV Partnership and others v HMRC)

FTT allowed film partnership tax deductions where payments were equity-funded but not debt-funded (Take 3.9 TV Partnership and others v HMRC)

Tax analysis: In Take 3.9 TV Partnership and others v HMRC , the First-Tier Tax Tribunal (FTT) allowed in part the appeals of five film partnerships,...

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

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 partnerships, limited liability partnerships (LLPs) and limited partnerships. In this note the term 'partner' should be read as including a member of an

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

Late payment penalties—inheritance tax

Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid

Strike out—making an application to strike out a statement of case

Strike out—making an application to strike out a statement of caseA strike out order can be made either following an application by the parties or on the court's own initiative. This Practice Note deals with the scenario of the order being made following a party's application.Making an application