Business structures

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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
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
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
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
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
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
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...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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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
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
By virtue of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 any...
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5th May
Practice notes
This Practice Note considers the UK tax aspects of the application of the UK’s transfer pricing rules to joint ventures, including in particular, when...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 4th May
Practice notes
This Practice Note considers the key tax issues arising when structuring, operating and terminating an international joint venture, over and above...
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Produced in partnership with Zoe Feller and Andrew Rink of Bird & Bird 4th May
Practice notes
Many companies operate in groups, broadly meaning that they are under common economic ownership. The existence of groups of companies is recognised in...
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4th May
Practice notes
Trustees are generally treated as UK resident if all the trustees are resident in the UK, or:•at least one trustee is resident in the UK•there is a...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 27th Apr
Practice notes
The security agentIn a syndicated loan transaction, the security agent (sometimes also known as the security trustee) (the Security Agent) will hold...
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26th Apr
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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Produced in partnership with Martin Blake of Farrer & Co 26th Apr
Practice notes
This Practice Note is about the tax treatment of a general partnership formed under English law (as opposed to a limited partnership, a limited...
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26th Apr
Practice notes
FORTHCOMING CHANGE relating to carry-back of losses: At Spring Budget 2021, the government announced a temporary extension of the period over which...
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26th Apr
Practice notes
This Practice Note considers the UK tax aspects of the operation and termination of a joint venture operated through a partnership. It is assumed for...
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Produced in partnership with Arun Birla of Paul Hastings, Hannah Gray of Paul Hastings and Abigail Hung of Paul Hastings 26th Apr
Practice notes
This Practice Note considers how the principal UK tax aspects of the establishment, operation and termination of a joint venture may impact on the...
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Produced in partnership with Arun Birla of Paul Hastings, Hannah Gray of Paul Hastings and Abigail Hung of Paul Hastings 26th Apr
Practice notes
This Practice Note considers the UK tax aspects of the establishment, operation and termination of contractual joint ventures, and also considers how...
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Produced in partnership with Arun Birla of Paul Hastings, Hannah Gray of Paul Hastings and Abigail Hung of Paul Hastings 26th Apr
Q&As
Section 30B of the Taxes Management Act 1970 (TMA 1970) permits HMRC, subject to various conditions, to amend a partnership’s tax return so as to...
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Produced in partnership with Denis Edwards of Normanton Chambers 26th Apr
Precedents
1Definitions and interpretation1.1In this Agreement, unless the context otherwise requires the following expressions shall have the following...
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Produced in partnership with Arun Birla of Paul Hastings, Hannah Gray of Paul Hastings and Abigail Hung of Paul Hastings 26th Apr
Practice notes
When one or more individuals decide to start a business, they have a choice as to what vehicle they operate that business through. In addition to the...
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22nd Apr
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2021, Finance Bill 2021 provides that the corporation tax rate will:•increase to 25%, from 1 April...
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22nd Apr
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 20th Apr
Practice notes
Not all bond issues involve a trustee. It is up to the issuer to decide whether to appoint a trustee or a fiscal agent—see Practice Note: Transaction...
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19th Apr
Practice notes
This Practice Note considers the UK tax aspects of the establishment of a joint venture operated through a partnership. It is assumed for the purposes...
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Produced in partnership with Arun Birla of Paul Hastings, Hannah Gray of Paul Hastings and Miss Abigail Hung of Paul Hastings 18th Apr
Practice notes
A non-UK resident company doing business in the UK has a choice as to whether to form a subsidiary company in the UK, or to operate through a...
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15th Apr

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