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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
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
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
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
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
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
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...
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9th Nov
Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC is consulting until 16 December 2020 on draft...
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9th Nov

Most recent Basic principles content

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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16th 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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15th 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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15th May
Practice notes
Companies with investment business and investment companiesThis Practice Note deals with the specific tax meanings of companies with investment...
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15th May
Practice notes
Property income—the corporation tax chargeThe charge to UK corporation tax applies to the profits of both UK and overseas property business.A property...
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15th May
Practice notes
What is the basis of corporation tax?FORTHCOMING CHANGE: As announced at Spring Budget 2021, Finance Bill 2021 provides that the corporation tax rate...
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15th May
Practice notes
Corporation tax surcharge on banking companiesWith effect from 1 January 2016, banking companies and building societies have been required to pay a...
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Produced in partnership with Andrew Loan of Fieldfisher LLP 15th May
Practice notes
Basis of calculation of corporation taxCorporation tax is charged on the profits of an accounting period of a company (and certain other entities)...
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15th May
Practice notes
Bank levyIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 15th 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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15th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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15th May
Practice notes
How is a UK permanent establishment taxed?A non-UK resident company trading in the UK through a permanent establishment (PE) will be chargeable to...
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15th May
Practice notes
What is a trade for tax purposes?A company is subject to corporation tax on the profits of its trade or trades in accordance with the rules found in...
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15th May
Practice notes
How intangible fixed assets are taxed—basic principlesThe intangible fixed asset regimeCompanies within the charge to corporation tax are generally...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 15th May
Practice notes
Compensation payments made by banks—non-deductibility and notional trade receiptThis Practice Note outlines the rule that, with effect from 8 July...
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Produced in partnership with Andrew Loan of Fieldfisher 15th May
Practice notes
Taxation in corporate insolvency—the principal issues in outlineTaxation and insolvencyThere are relatively few specific rules governing the UK...
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Produced in partnership with David L. Irvine of Goodwin, Nathan Langford of Kirkland & Ellis International LLP and Philip Ridgway of Temple Tax Chambers 15th May
Practice notes
Taxation of trading profits—basis, receipts and deductionsOnce a company has established that it has a trade (for which see Practice Note: What is a...
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15th 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
Any company, whether public or private, can apply to the Registrar of Companies to be struck off the register of companies and dissolved. For more...
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15th Feb
Q&As
In answering this Q&A, we have assumed that the person in question is a UK resident and domiciled person carrying on a sole trade (ie not in...
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15th Feb

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