Tax groupings

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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 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 9th Nov
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 9th Nov
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 9th Nov
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 9th Nov
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
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 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 9th Nov
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

Most recent Tax groupings content

Practice notes
This Practice Note is about the rules for establishing whether companies are within the same group for the purposes of corporation tax on chargeable...
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29th Sep
Q&As
Can an entity be a ‘connected [person]’ as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an ‘associated company’ with the...
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29th Sep
Practice notes
FORTHCOMING CHANGE: On 28 August 2020 HMRC published a call for evidence to explore the impact of potential changes to the rules on VAT grouping, in...
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28th Sep
Practice notes
Why does it matter?It is common for corporate entities to operate within a group, ie several companies under common ownership. The basic UK...
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26th Sep
Practice notes
Relief from stamp duty is available where beneficial ownership of stock or marketable securities is transferred between two bodies corporate that are...
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26th Sep
Practice notes
Consortium relief is an extension of the group relief rules to allow the surrender and claim of losses between companies that are not so closely...
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26th Sep
Practice notes
An exemption from stamp duty land tax (SDLT) can be claimed where an interest in land is acquired (a land transaction) by one body corporate (referred...
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26th Sep
Practice notes
The general rule is that:•the credits (broadly, but not necessarily, profits), and•debits (broadly, but not necessarily, losses)arising to a company...
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26th Sep
Practice notes
Groups of companiesA number of reliefs in respect of intangible fixed assets depend on membership of a group. For example, where there is a disposal...
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26th Sep
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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25th Sep

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