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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
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 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
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
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
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
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
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 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
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
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
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
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
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
Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Companies and corporation tax content

Practice notes
PSC register—the people with significant control regimeCoronavirus (COVID-19) IMPACT: Certain aspects of the PSC regime are affected by temporary...
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14th May
Practice notes
How are individuals taxed on distributions received from companies?This Practice Note explains the rules that apply to distributions made to UK...
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13th May
Practice notes
How are individuals taxed on distributions received from non-UK resident companies prior to 6 April 2016? [Archived]ARCHIVED: This Practice Note has...
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13th May
Practice notes
When does the UK tax non-resident companies?When a company that is resident outside the UK starts doing business in the UK, it will want to know...
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13th May
Practice notes
Capital gains for connected personsThe capital gains legislation includes specific provisions for persons who are connected with one another. These...
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13th May
Practice notes
When a company is UK tax residentA company is UK tax resident if it is:•incorporated in the UK (subject to exceptions), or•centrally managed and...
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13th May
Practice notes
Attribution of gains to participators in non-UK companiesThis Practice Note is about the rules that can impose a charge to tax on UK persons holding...
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13th May
Practice notes
Tax consequences for close companiesSummary of tax considerationsThe concept of a close company is intended to capture those companies that are...
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13th May
Practice notes
Non-resident CGT—summary [Archived]ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 13th May
Practice notes
Profit fragmentation and tax avoidanceFrom April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual...
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13th May
Q&As
Is a wife, Mrs X, connected (within section 1122 of the Corporation Tax Act 2010 (CTA 2010)) with a company wholly owned by her husband, Mr X? Are all...
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13th May
Q&As
What are the CGT and SDLT implications of a bare trustee (mother) transferring the entire trust property comprising a number of residential properties...
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13th May
Q&As
If a property, subject to a mortgage, is to be transferred, is the consideration for the purposes of capital gains tax and stamp duty land tax the...
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13th May
Practice notes
This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of...
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10th May
Practice notes
Auction processes play an important role in particular industries, for example, in the private equity industry, in government privatisations, or in...
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6th May
Practice notes
Auction processes play an important role in particular industries, for example, in the private equity industry or in government privatisations, or in...
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6th May
Practice notes
FORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D) reliefs, beginning with a...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 5th May
Precedents
[Date][Transferor's name and Unique Taxpayer Reference (UTR)][Transferee's name and UTR]Election to apportion the price of fixtures under section 198...
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Produced in partnership with Martin Wilson 5th May
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 5th May
Practice notes
A taxpayer may be able to obtain tax relief for expenditure on fixtures by claiming plant and machinery allowances. For more on the availability of...
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Produced in partnership with Martin Wilson 5th May

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