Partnerships

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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 is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
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
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
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 Partnerships content

Practice notes
A general partnership is treated, for VAT purposes, as though it were a separate taxable person.This note is about:•the nature of a partnership, and...
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9th Apr
Practice notes
A 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...
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9th Apr
Practice notes
This Practice Note sets out the general treatment of partnerships for stamp duty land tax (SDLT) purposes, including what amounts to a partnership for...
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Produced in partnership with Kevin Griffin 9th Apr
Practice notes
This Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general partnerships, limited liability...
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9th Apr
Practice notes
This Practice Note sets out the specific stamp duty land tax (SDLT) rules which apply to property investment partnerships (PIPs). It explains the...
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Produced in partnership with Kevin Griffin 9th Apr
Practice notes
This Practice Note explains the special stamp duty land tax (SDLT) rules which apply when an interest in land is transferred from a partnership to a...
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9th Apr
Practice notes
Along with limited partnerships (LPs), limited liability partnerships (LLPs) are used as vehicles for holding UK real estate.This Practice Note...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
Partnerships are often used as vehicles for holding UK real estate. The forms of partnership used are generally limited partnerships (LPs) and limited...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
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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9th Apr
Practice notes
This Practice Note gives details of stamp duty land tax (SDLT) anti-avoidance rules and SDLT reliefs which apply specifically to transactions of...
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Produced in partnership with Kevin Griffin 9th 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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9th 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, Hannah Gray and Abigail Hung of Paul Hastings (Europe) LLP 9th Apr
Q&As
The off-payroll IR35 regime applies to engagements under which:•an individual personally performs (or is obligated to personally perform) services for...
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16th Mar
Practice notes
This Practice Note considers specific tax provisions relevant only to a limited partnership formed under English law (as opposed to a general...
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16th Mar
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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12th Mar
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 Miss Abigail Hung of Paul Hastings 2nd Mar
Q&As
The provisions relating to additional dwelling supplement (ADS) for land and buildings transaction tax (LBTT) are contained in Schedule 2A to the Land...
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Produced in partnership with Ronnie Brown of Burness Paull 15th Feb
Q&As
In answering this Q&A, it has been assumed that members of the limited liability partnership (LLP) are not employees of the LLP and that the salaried...
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15th Feb
Q&As
Tax transparencyA general or limited partnership is not taxable in its own right. Instead the partners are taxable on their share of the partnership's...
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15th Feb

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