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Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

The following Commercial news provides comprehensive and up to date legal information on Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

The following Tax news provides comprehensive and up to date legal information on Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

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...

International movement of capital

The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...

Value shifting

The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...

Practice notes

Property authorised investment funds (PAIFs)—summary

The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...

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

Types of lending

Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...

9th Nov

Practice notes

VAT treatment of damages and compensation payments

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...

9th Nov

In-house

Practice notes

Direct tax treatment of damages and compensation payments

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...

9th Nov

Practice notes

What is a tax determination?

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...

Produced in partnership with Philip Rutherford 12th Jan

Practice notes

Schemes of reconstruction defined

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...

9th Nov

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan

In-house

Practice notes

Capital reduction demergers

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:...

Produced in partnership with Zoe Feller of Bird & Bird 12th Jan

Practice notes

Why have a tax covenant?

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...

9th Nov

Practice notes

VAT on composite supplies

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...

Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan

Practice notes

Unilateral relief for foreign tax

Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...

9th Nov

Practice notes

Bank levy

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...

Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan

Practice notes

VAT—triangulation

Brexit: This Practice Note contains information on subjects impacted by the UK’s withdrawal from the EU. The Taxation (Cross-border Trade) Act 2018,...

Produced in partnership with John Fuszard of Sagars Accountants Ltd 12th Jan

Practice notes

SDLT—deeds of rectification

Stamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that...

9th Nov

Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...

9th Nov

Practice notes

What is an intangible fixed asset?

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...

Produced in partnership with Anne Fairpo of Temple Tax Chambers 12th Jan

Most recent Corporate law for tax lawyers content

Practice notes

Structuring a takeover—offers vs schemes of arrangement

Structuring a takeover—offers vs schemes of arrangementThis Practice Note contrasts and compares the principal features of the two most commonly...

Produced in partnership with Julian Henwood of Gowling WLG 15th May

Practice notes

Preparing a company for admission to AIM

Preparing a company for admission to AIMThis Practice Note examines the keys steps and issues that a company will need to take and consider prior to...

15th May

Practice notes

Requirements for listing on the Official List of the Financial Conduct Authority

Requirements for listing on the Official List of the Financial Conduct AuthorityThis Practice Notice focuses on the two segments of the UK listing...

15th May

Practice notes

Asset purchases

Asset purchasesA business can be acquired by one of two methods: an asset purchase or a share purchase. The two types of transaction are fundamentally...

15th May

Practice notes

Financing an acquisition—share and asset purchases

Financing an acquisition—share and asset purchasesThe buyer may fund the acquisition by way of:•cash: from its internal cash resources (or those of...

15th May

Practice notes

Share buybacks—the legal framework

Share buybacks—the legal frameworkA limited company may buy back shares in itself, if certain conditions set out in the Companies Act 2006 (CA 2006)...

15th May

Practice notes

The nature of a limited partnership and its legal framework

The nature of a limited partnership and its legal frameworkSources of limited partnership lawThe main body of law governing a limited partnership...

15th May

Practice notes

Incorporating a company

Incorporating a companyCoronavirus (COVID-19): Following the COVID-19 outbreak, some Companies House filing and other administrative procedures have...

15th May

Practice notes

PSC register—the people with significant control regime

PSC register—the people with significant control regimeCoronavirus (COVID-19) IMPACT: Certain aspects of the PSC regime are affected by temporary...

15th May

Scottish Law

Practice notes

Coronavirus (COVID–19)—impact on company filing and administrative procedures

Coronavirus (COVID–19)—impact on company filing and administrative proceduresThis Practice Note summarises the key ways in which company filing and...

15th May

COVID-19

Practice notes

Open offers

Open offersThis Practice Note focuses on the key aspects of open offers and the matters that require consideration when an open offer is being carried...

Produced in partnership with James Ufland of Slaughter and May and Chris McGaffin of Slaughter and May 15th May

Practice notes

Auction sales—share purchase

Auction sales—share purchaseAuction processes play an important role in particular industries, for example, in the private equity industry, in...

15th May

Practice notes

Rights issues—key considerations

Rights issues—key considerationsThis Practice Note focuses on the key legal considerations when a rights issue is being carried out by a company...

Produced in partnership with James Ufland of Slaughter and May and Chris McGaffin of Slaughter and May 15th May

Practice notes

Coronavirus (COVID-19)—impact on annual accounts and reports

Coronavirus (COVID-19)—impact on annual accounts and reportsBackgroundThis Practice Note considers the impact that the coronavirus (COVID-19) pandemic...

15th May

COVID-19

Practice notes

Tailoring a shelf company

Tailoring a shelf companyA person wishing to set up a new company has the following options:•they can incorporate a new company in accordance with the...

15th May

Practice notes

Holding treasury shares

Holding treasury sharesA limited company may hold, or deal with, shares in itself, if certain conditions set out in the Companies Act 2006 (CA 2006)...

15th May

Practice notes

Types of secondary offers

Types of secondary offersIntroductionWhere a company:•listed on the Official List of the Financial Conduct Authority and admitted to trading on the...

Produced in partnership with Chris McGaffin of Slaughter and May. 15th May

Practice notes

Warranty and indemnity (W&I) insurance in M&A transactions

Warranty and indemnity (W&I) insurance in M&A transactionsWarranty and indemnity (W&I) insurance may be used in private company sale and purchase...

Produced in partnership with Mary Duffy of AIG 15th May

Practice notes

Preparing a company for listing on the Official List and admission to trading on the Main Market

Preparing a company for listing on the Official List and admission to trading on the Main MarketThis Practice Note examines the key steps and issues...

15th May

Practice notes

Private company redemptions of shares—initial considerations

Private company redemptions of shares—initial considerationsA limited company that proposes to carry out a redemption of redeemable shares must comply...

15th May

Corporate law for tax lawyers

View Tax by content type:

Latest Tax News

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Tax weekly highlights—13 May 2021

Contracts—‘Reasonable detail’ in notice clause determined by business purpose (Dodika Ltd and others v United Luck Group Holdings Ltd)

Taxpayer’s Ramsay argument fails before the Court of Appeal (Khan v HMRC)

Featured Tax content

Tax considerations on a loan agreement—the tax indemnity clause

International movement of capital

Clause—tax gross up—commercial agreements

Value shifting

Most recent Corporate law for tax lawyers content

Popular documents

Introduction to passing off

Term Loan B facilities

What is a statutory declaration of solvency, and what happens if a false declaration of solvency is made

Breach of statutory duty

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