Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
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...
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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...
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...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
IntroductionMany trusts own shares as part of a portfolio of investments. This Practice Note looks at situations where trustees own shares in order to...
Not all bond issues involve a trustee. It is up to the issuer to decide whether to appoint a trustee or a fiscal agent—see Practice Note: Transaction...
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESTrustees may be subject to personal liability if they commit a breach of trust...
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESIndividual trustees v corporate trusteeThe most common trustee structures used...
Overview of potential IHT chargesIt is important when establishing or operating an employee benefit trust (EBT) that the potential for Inheritance Tax...
The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship created by a person, the settlor, when...
For general information on Guernsey, see Practice Note: Private Client jurisdictional guide—Guernsey.Guernsey as a trust jurisdictionWhilst there are...
The examples given in this Practice Note are based on a UK company that is privately owned but the same issues arise for families who own other types...
The use of special purpose vehicle structures is very common in aviation finance. They provide various advantages for lenders such as tax benefits and...
What is a Quistclose trust?A Quistclose trust is an example of an ‘automatic’ resulting trust, ie a trust which arises where property is transferred...
The security agentIn a syndicated loan transaction, the security agent (sometimes also known as the security trustee) (the Security Agent) will hold...
We refer you to the following Practice Note which you may find useful for your purposes: The security agent and security trust provisions.It is quite...
Sign-in
Help
In-house
