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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
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 12th Jan
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
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 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
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 Clause bank for tax lawyers content

Precedents
Intellectual Property Rights means copyright, rights related to copyright such as moral rights and performers rights, patents,...
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8th Jan
Precedents
1Capital allowances1.1In this clause 1:CAA 2001•means Capital Allowances Act 2001Fixtures•means those items forming part of the Tenant’s Works which...
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Produced in partnership with Martin Wilson 8th Jan
Precedents
1 VAT 1.1 Definitions In this clause: HMRC means HM Revenue and Customs VAT means United Kingdom value...
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8th Jan
Precedents
1Capital allowances—for use where the Seller has claimed plant and machinery allowances and the parties will enter into a s 198/s 199 election on...
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Produced in partnership with Martin Wilson 8th Jan
Precedents
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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17th Dec
Precedents
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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17th Dec
Precedents
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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17th Dec
Precedents
1Deductions from payments and indemnity for tax deductions1.1[Subject to anything to the contrary in this Agreement,] the Company shall make all...
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1st Dec
Precedents
1Definitions and interpretation1.1In this Agreement, unless the context otherwise requires the following expressions shall have the following...
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29th Nov
Precedents
1Compliance1.1ReturnsThe Company has duly and properly submitted all [material] computations and returns (including all land transaction returns),...
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29th Nov
Precedents
Definitions HMRC Her Majesty’s Revenue and Customs Lease the lease of the Property dated [insert date] and made between...
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26th Sep
Precedents
Definitions Deferred SDLT has the meaning as set out in clause [insert number] HMRC Her Majesty’s Revenue and...
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26th Sep
Precedents
1 Redemption and purchase 1.1 Redemption for tax reasons The Bonds may be redeemed at the option of the Issuer in...
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26th Sep
Precedents
Tax or Taxation...
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26th Sep
Precedents
United Kingdom Taxation Certain UK tax considerations The following statements, which are intended as a general guide only[ and...
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26th Sep
Precedents
United Kingdom Taxation General The following paragraphs, which are intended as a general guide only [and not a substitute for...
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26th Sep
Precedents
1 VAT 1.1 Unless otherwise stated in this Agreement: 1.1.1 all references in this Agreement to the...
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26th Sep
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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26th Sep
Precedents
1 Compliance 1.1 Returns The Company has duly and properly submitted all [material] computations and returns...
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26th Sep

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