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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
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
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
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 regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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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 12th Jan
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
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 Execution content

Precedents
Option 1—deed executed by an overseas company under its common seal, where one authorised signatory must sign the document that the...
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26th Sep
Precedents
Option 1—contract signed on behalf of an overseas company, where the authorised signatory is an individual Signed by [insert name...
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26th Sep
Precedents
Option 1—deed executed by each partner in the presence of a witness Executed as a deed by [insert name of partner] for and on...
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26th Sep
Precedents
Option 1—deed executed by a limited liability partnership under its common seal, where the limited liability partnership agreement...
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26th Sep
Precedents
Option 1—contract signed on behalf of a limited liability partnership Signed by [insert name of member or other authorised...
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26th Sep
Precedents
Option 1—deed executed by an individual general partner in the presence of a witness Executed as a deed by [insert name of...
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26th Sep
Precedents
Option 1—deed executed by an individual in the presence of a witness Executed as a deed by [insert name of individual] in the...
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26th Sep
Precedents
Option 1—contract signed on behalf of a company, where the authorised signatory is an individual Signed by [insert name of...
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26th Sep
Precedents
Option 1—contract signed by an individual general partner ...
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26th Sep
Precedents
Option 1—deed executed by a company under its common seal (model articles, where the authorised signatory is an...
Read More >
26th Sep
Precedents
Option 1—deed executed by an individual attorney in the presence of a witness Executed as a deed by [insert name of individual]...
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26th Sep
Precedents
Option 1—contract signed by individual attorney Signed by [insert name of individual attorney] as attorney for [insert name of...
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26th Sep

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