Explore the complexities of choosing and structuring business entities to optimise tax efficiency, compliance, and liability protection. Our expert-guided insights help you navigate regulations, advise on suitable frameworks, and strategise for tax planning. Ideal for legal practitioners seeking to provide robust, informed guidance to their business clients.
This week's edition of Tax weekly highlights includes: (1) UK Finance responding to HMRC’s consultation on simplifying treaty relief for overseas...
Tax analysis: In Poznic, the First-tier Tax Tribunal (FTT) held that the taxpayer’s disposal of B ordinary shares did not qualify for business asset...
Tax analysis: In Cogefin, the First-tier Tax Tribunal (FTT) held that a Bermudian company was UK resident because its central management and control...
Tax analysis: In Jody Scheckter v HMRC, the First-tier Tax Tribunal (FTT) dismissed the taxpayer’s appeal concerning his entitlement to claim sideways...
VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....
The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...
What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...
If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the...
Taxation of limited partnershipsThis Practice Note considers specific tax provisions relevant only to a limited partnership formed under English law (as opposed to a general partnership, a limited liability partnership (LLP) or a limited partnership formed under Scottish law).Like a general
Priority between loss reliefs in loss making companiesWhy does it matter?A company that is a member of a group and has incurred any of the types of losses available for surrender by way of group relief may, without any further rules, have more than one way in which to use the loss. There are a
Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid
Strike out—making an application to strike out a statement of caseA strike out order can be made either following an application by the parties or on the court's own initiative. This Practice Note deals with the scenario of the order being made following a party's application.Making an application
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