Basic principles

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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
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 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 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
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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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
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 Basic principles content

Practice notes
Taxation and insolvencyThere are relatively few specific rules governing the UK taxation of companies that are subject to insolvency procedures. The...
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Produced in partnership with David L. Irvine, Nathan Langford of Kirkland & Ellis International LLP and Philip Ridgway of Temple Tax Chambers 27th Jan
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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26th Jan
Practice notes
A company is UK tax resident if it is:•incorporated in the UK (subject to exceptions), or•centrally managed and controlled in the UKprovided it is not...
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18th Jan
Practice notes
When a company that is resident outside the UK starts doing business in the UK, it will want to know whether and to what extent the activities of that...
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15th Jan
Practice notes
The intangible fixed asset regimeCompanies within the charge to corporation tax are generally subject to the intangible fixed assets regime (the IFA...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 15th Jan
Practice notes
Once a company has established that it has a trade (for which see Practice Note: What is a trade for tax purposes?), it is required to calculate the...
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15th Jan
Practice notes
A non-UK resident company trading in the UK through a permanent establishment (PE) will be chargeable to corporation tax on the profits associated...
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15th Jan
Practice notes
Summary of tax considerationsThe concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and...
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15th Jan
Practice notes
The charge to UK corporation tax applies to the profits of both UK and overseas property business.A property business is one that generates income...
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15th Jan
Practice notes
This Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act 2010 (CTA 2010). An almost...
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15th Jan
Practice notes
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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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 11th Jan
Practice notes
With effect from 1 January 2016, banking companies and building societies have been required to pay a surcharge of 8% on their taxable profits...
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Produced in partnership with Andrew Loan of Fieldfisher LLP 8th Jan
Practice notes
This Practice Note outlines the rule that, with effect from 8 July 2015 (or 15 July 2015 in the case of corporate partners):•prevents banking...
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Produced in partnership with Andrew Loan of Fieldfisher 8th Jan
Practice notes
Corporation tax is charged on companies (and certain other bodies) that are resident in the UK on their income and gains in each accounting period,...
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10th Dec
Practice notes
This Practice Note deals with the specific tax meanings of companies with investment business and investment companies, rather than any more generic...
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29th Nov
Practice notes
Corporation tax is charged on the profits of an accounting period of a company (and certain other entities) within the charge to UK corporation tax....
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29th Nov
Practice notes
A company is subject to corporation tax on the profits of its trade or trades in accordance with the rules found in sections 34–201, Part 3 of the...
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29th Nov
Q&As
This Q&A considers whether exploitation of intellectual property (IP) can be a trading activity so that it is a ‘trading company’ for the purposes of...
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29th Nov
Q&As
To properly consider whether a person is connected with another person for the purposes of sections 1122 and 1123 of the Corporation Tax Act 2010 (CTA...
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29th Nov

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