Business structures and reorganisations

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Business structures and reorganisations guidance:

HMRC—Stamp Office [insert HMRC Stamp Office address] Application for stamp duty group relief under section 42 of the Finance Act 1930 (as amended) in the matter of a...

Precedents

FORTHCOMING CHANGE relating to transfers within an EU group: Finance Bill 2020 is expected to contain provisions permitting companies to pay tax in instalments in...

Practice Note

FORTHCOMING CHANGE on amendments to FA 1986, s 77A: Finance Bill 2019–20 amends, with effect from Royal Assent, section 77A of Finance Act 1986 (FA 1986) to ensure that...

Practice Note

Produced in partnership with Robert Langston of Saffery Champness [Team Leader] [insert HMRC address] [insert date] Application for clearance[s] in advance under section...

Precedents

[Team Leader] [insert HMRC address] [insert date] Application for clearances in advance under [section[s] 138[ and 139(5)] Taxation of Chargeable Gains Act 1992][ and...

Precedents

This Practice Note outlines the tax issues that are relevant where creditors seek to enforce their security over the assets of a company, or corporate group, in distress....

Practice Note

The economic climate can lead to instances of distressed debt portfolios changing hands. In such a climate, typically banks seek to reduce their balance sheet exposure to...

Practice Note

This Practice Note outlines the tax issues that should be considered when a company seeks to restructure its external debt obligations. Other Practice Notes in this...

Practice Note

A demerger means the separation of a company’s business into two or more parts, typically carried on by successor companies under the same ownership as the original...

Practice Note

HM Revenue and Customs [insert address] [insert date] Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992 This election is made jointly by [insert...

Precedents

Why does it matter? It is common for corporate entities to operate within a group, ie several companies under common ownership. The basic UK corporation tax rules operate...

Practice Note

This Practice Note covers: • what arrangements under Insolvency Act 1986 (IA 1986), s 110 (a s 110 arrangement) is (see: What is a s 110 arrangement?) • the rationale for...

Practice Note

Introduction Many significant and valuable UK buildings are held in Jersey Property Unit Trusts (JPUTs), sometimes referred to as Jersey Unit Trusts. This practice note...

Practice Note

FORTHCOMING CHANGES relating to insolvency and tax: Finance Bill 2019–20 introduces provisions where: • with effect for business insolvencies that commence on or after 6...

Practice Note

FORTHCOMING CHANGES relating to insolvency and tax: Finance Bill 2019–20 introduces provisions where: • with effect for business insolvencies that commence on or after 6...

Practice Note

This Practice Note: • outlines the main UK tax provisions that apply where a fixed charge receiver sells assets owned by a company, and • answers the important issues...

Practice Note

This Practice Note outlines the main tax implications where a company implements a company voluntary arrangement (CVA) under Part I of the Insolvency Act 1986 (IA 1986)....

Practice Note

FORTHCOMING CHANGE on amendments to FA 1986, s 77A: Finance Bill 2019–20 amends, with effect from Royal Assent, section 77A of Finance Act 1986 (FA 1986) to ensure that...

Practice Note

FORTHCOMING CHANGES relating to insolvency and tax: Finance Bill 2019–20 introduces provisions where: • HMRC becomes a secondary preferential unsecured creditor (moving...

Practice Note

Part 14 of the Corporation Tax Act 2010 (CTA 2010) (the Part 14 rules) contains anti-avoidance provisions designed to stop a profitable organisation from reducing its...

Practice Note

This Practice Note is about the meaning of a scheme of reconstruction for tax purposes. Tax neutrality is maintained where a company (company A) enters into an...

Practice Note

Some company acquisitions that involve a corporate buyer will be structured so that the consideration payable is the issue of new shares and/or loan notes by the buying...

Practice Note

This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of reconstruction. Relief from tax...

Practice Note

FORTHCOMING CHANGE on amendments to FA 1986, s 77A: Finance Bill 2019–20 amends, with effect from Royal Assent, section 77A of Finance Act 1986 (FA 1986) to ensure that...

Practice Note

This Practice Note is about the tax implications of a statutory demerger. The most straightforward way to carry out a demerger involves a company (the target company)...

Practice Note

This Practice Note is about the following aspects of the tax rules on statutory (ie dividend) demergers: • the anti-avoidance rules concerning chargeable payments, and •...

Practice Note
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