Business structures

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Practice notes
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...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
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
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
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
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
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
Practice notes
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
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
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
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
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
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
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
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
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 Business structures content

Q&As
This Q&A considers a UK resident trust.See Practice Note: Trust expenses, which includes a discussion on income expenses and capital expenses.Although...
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22nd Jan
Practice notes
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...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 22nd Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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20th Jan
Practice notes
BREXIT: As of 31 January 2020, the UK is no longer an EU Member State, but has entered an implementation period during which it continues to be...
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17th Jan
Practice notes
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESIndividual trustees v corporate trusteeThe most common trustee structures used...
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16th Jan
Practice notes
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESTrustees may be subject to personal liability if they commit a breach of trust...
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Produced in partnership with Elizabeth Haggis of Excuria Law 16th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 15th Jan
Practice notes
For general information on Guernsey, see Practice Note: Private Client jurisdictional guide—Guernsey.Guernsey as a trust jurisdictionWhilst there are...
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Produced in partnership with Gavin Ferguson of Ogier 15th Jan
Practice notes
For general information on Jersey, see Practice Note: Private Client jurisdictional guide—Jersey [Archived].Legal frameworkThe legal framework for...
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Produced in partnership with Mr David Dorgan 15th Jan
Practice notes
When looking at the definition of chargeable transfers and transfers of value in the Inheritance Tax Act 1984 (IHTA 1984), it is perhaps not...
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Produced in partnership with Katya Vagner of PwC 15th Jan
Practice notes
For general information on the Isle of Man, see Practice Note: Private Client jurisdictional guide—Isle of Man.Legal frameworkIsle of Man trust law...
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Produced in partnership with Erin Trimble-Cregeen and Melissa Wong of Appleby (Isle of Man) LLC 15th Jan
Practice notes
IntroductionMany trusts own shares as part of a portfolio of investments. This Practice Note looks at situations where trustees own shares in order to...
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Produced in partnership with Marilyn McKeever, Partner at New Quadrant Partners 15th Jan
Practice notes
This Practice Note was originally drafted by Owen Clutton of Macfarlanes LLP but is now maintained by Lexis®PSL Private Client.Trustee residence...
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15th Jan
Practice notes
This Practice Note was originally drafted by Christopher Kerr-Smiley, Legal Director at Womble Bond Dickinson, but is now maintained by Lexis®PSL...
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15th Jan
Practice notes
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...
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15th Jan
Practice notes
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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15th Jan
Practice notes
What is outsourcing?Outsourcing is an arrangement whereby one company provides services to another company that could be, or usually have been,...
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15th Jan
Practice notes
Companies can be treated as forming groups for many different tax purposes. The usual principle behind group treatment is that the companies which...
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15th Jan
Practice notes
Coronavirus (COVID-19): For information on the inadvertent creation of permanent establishments as a result of the coronavirus pandemic, see Q&A:...
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15th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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15th Jan

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