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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
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...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Basic principles content

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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6th Sep
Q&As
When a non-UK company has a UK permanent establishment or becomes UK tax resident, how and when must it inform Companies House and HMRC? What happens...
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6th Sep
Practice notes
Bank levyIP COMPLETION DAY: The Brexit transition period ended at 11pm on 31 December 2020. At this time (referred to in UK law as ‘IP completion...
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Produced in partnership with Charlotte L. Sallabank 5th Sep
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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31st Aug
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 22nd Aug
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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16th Aug
Q&As
When is a person connected with another person within sections 1122 and 1123 of the Corporation Tax Act 2010?To properly consider whether a person is...
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16th Aug
Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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16th Aug
Q&As
Are the tax implications of a company liquidation the same as where the company is voluntarily struck off?Any company, whether public or private, can...
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16th Aug
Q&As
Will HMRC allow relief of a loan to a participator charge where the benefit of a loan due to the participator (that is of equal or greater value) is...
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16th Aug
Q&As
Would a limited liability partnership be classified as a company for the purposes of determining connected persons under section 1122 of the...
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16th Aug
Q&As
Can the sole director of a limited company be responsible for the company’s unpaid tax debts? If the sole director dies intestate, will their personal...
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16th Aug
Q&As
How is non-monetary compensation received by a company in return for providing services as part of its trade treated for corporation tax...
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16th Aug
Q&As
Can a self-employed dentist deduct the costs of a leased vehicle in calculating income tax liability?In answering this Q&A, we have assumed that the...
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16th Aug
Q&As
Can the exploitation of intellectual property be a trading activity for the purposes of entrepreneurs’ relief?This Q&A considers whether exploitation...
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16th Aug
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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15th Aug
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 Aug
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 Aug

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