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Practice notes
Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...
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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 19th May
Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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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
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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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
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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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
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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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
Why have a tax covenant?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...
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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

Most recent Trusts in commercial settings content

Q&As
Can a company which is wholly owned by a trust be appointed as a trustee of that trust?This Q&A assumes that:•the company is incorporated under...
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15th Jul
Q&As
If a trust’s sole asset is shares in a private company, how can expenses of the trust be paid without the trustees receiving a dividend, or borrowing...
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15th Jul
Q&As
What information do you have concerning the execution of guarantees by trustees?For the purposes of this Q&A it is assumed that:•the trust in question...
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15th Jul
Practice notes
Taking security from trust fundsIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered...
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Produced in partnership with Martin Blake of Farrer & Co 13th Jul
Practice notes
Employee benefit trusts—on-shore and offshore trusts and tax implicationsTrustees are generally treated as UK resident if all the trustees are...
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Produced in partnership with Jeremy Glover (Share Schemes) 1st Jul
Practice notes
The security agent and security trust provisionsThe security agentIn a syndicated loan transaction, the security agent (sometimes also known as the...
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14th Jun
Practice notes
What is an employee benefit trust?The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship...
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Produced in partnership with Jeremy Glover (Share Schemes) 11th Jun
Q&As
Does an employee benefit trust have to be registered with HMRC’s online Trust Registration Service?By virtue of the Money Laundering, Terrorist...
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6th Jun
Q&As
What issues (tax and non-tax) need to be considered if a majority shareholder wishes to leave their shareholding on a qualifying interest in...
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5th Jun
Q&As
How should the people with significant control (PSC) conditions be applied in the context of an individual holding shares on trust for a minor?The...
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5th Jun
Practice notes
Employee benefit trusts and inheritance tax considerationsOverview of potential IHT chargesIt is important when establishing or operating an employee...
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5th Jun
Q&As
How can a third party enforce rights under a deed to which it is not a party?Privity of contract'Privity of contract' is a common law doctrine, which...
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5th Jun
Practice notes
Cayman Islands STAR trusts—common usesThis Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman...
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Produced in partnership with Mourant Ozannes and Carey Olsen 5th Jun
Practice notes
Trusts as a vehicle for holding company sharesIntroductionMany trusts own shares as part of a portfolio of investments. This Practice Note looks at...
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Produced in partnership with Marilyn McKeever, Partner at New Quadrant Partners 5th Jun
Q&As
Does a professional trustee, for example, a pension trustee, have to register at Companies House, a charge granted by it over property which it holds...
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5th Jun
Practice notes
Trustee liability and protection in pensionsTHIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESTrustees may be subject to personal...
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Produced in partnership with Elizabeth Haggis of Excuria Law 5th Jun
Practice notes
Types of pension trusteesTHIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESIndividual trustees v corporate trusteeThe most common...
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5th Jun
Practice notes
Quistclose trustsWhat is a Quistclose trust?A Quistclose trust is an example of an ‘automatic’ resulting trust, ie a trust which arises where property...
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5th Jun
Practice notes
Jersey trustsFor general information on Jersey, see Practice Note: Private Client jurisdictional guide—Jersey [Archived].Legal frameworkThe legal...
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Produced in partnership with Mr David Dorgan 5th Jun

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