Tax groupings

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Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
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 19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Tax groupings content

Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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31st Jul
Practice notes
SDLT—meaning of groupAn exemption from stamp duty land tax (SDLT) can be claimed where an interest in land is acquired (a land transaction) by one...
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31st Jul
Practice notes
Capital gains—groups of companiesThis Practice Note is about the rules for establishing whether companies are within the same group for the purposes...
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31st Jul
Practice notes
Group relief—loss relief groupWhy does it matter?It is common for corporate entities to operate within a group, ie several companies under common...
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31st Jul
Practice notes
Stamp duty—meaning of groupRelief from stamp duty is available where beneficial ownership of stock or marketable securities is transferred between two...
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31st Jul
Practice notes
Consortium reliefConsortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not...
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31st Jul
Practice notes
Taxation of loan relationships—intra-group transfersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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31st Jul
Practice notes
VAT groupsMany companies operate in groups, broadly meaning that they are under common economic ownership. The existence of groups of companies is...
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31st Jul
Practice notes
Impact of share sales on tax groupingsCompanies can be treated as forming groups for many different tax purposes. The usual principle behind group...
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31st Jul
Practice notes
What is an intangible fixed assets group?Groups of companiesA number of reliefs in respect of intangible fixed assets depend on membership of a group....
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Produced in partnership with Anne Fairpo 31st Jul

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