Business structures

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
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 12th Jan
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 12th Jan
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 12th Jan
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 12th Jan
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
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
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
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Business structures content

Practice notes
Summary of tax considerationsThe concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and...
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15th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 15th Jan
Practice notes
A general partnership is treated, for VAT purposes, as though it were a separate taxable person.This note is about:•the nature of a partnership, and...
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15th Jan
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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15th Jan
Practice notes
This Practice Note considers the UK tax aspects of the operation and termination of a joint venture operated through a limited liability company...
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Produced in partnership with Sara Stewart of Vinson & Elkins RLLP and Arun Birla, Hannah Gray and Abigail Hung of Paul Hastings (Europe) LLP 15th Jan
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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15th Jan
Practice notes
When a sole trader (or an individual running a business as a partner in a partnership) decides to incorporate that business, he transfers the assets...
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15th Jan
Practice notes
This Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act 2010 (CTA 2010). An almost...
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15th Jan
Practice notes
This Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general partnerships, limited liability...
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15th Jan
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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15th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Zoe Feller and Andrew Rink of Bird & Bird 15th Jan
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Martin Blake of Farrer & Co 12th Jan
Practice notes
The use of special purpose vehicle structures is very common in aviation finance. They provide various advantages for lenders such as tax benefits and...
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Produced in partnership with Norton Rose Fulbright 8th Jan
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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Produced in partnership with Anne Fairpo of Temple Tax Chambers 8th Jan
Practice notes
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...
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Produced in partnership with Ken McCracken 8th Jan
Q&As
There are two principal advantages in funding a joint venture company by way of debt rather than equity. However, these advantages need to be...
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Produced in partnership with Julian Henwood of Gowling WLG 8th Jan
Q&As
The application of the principles of the people with significant control (PSC) regime to family-owned businesses or any other circumstances where...
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9th Dec
Practice notes
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...
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30th Nov
Q&As
Non-tax reasons for holding a company in trustA shareholder trustee has all the same rights and duties of a shareholder who is absolutely entitled to...
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29th Nov

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