Basic principles

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Practice notes
FORTHCOMING CHANGE relating to SDLT for non-residents buying residential property: As announced at Budget 2018, confirmed at Spring Budget 2020 and...
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27th Oct
Practice notes
Once is has been determined that there is a notifiable transaction for SDLT purposes, it should be considered whether any reliefs or exemptions are...
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21st Oct
Practice notes
The sale of a 'business' is really a sale of assets bundled together. VAT would therefore be charged on the transfer of each asset in accordance with...
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Produced in partnership with Cathya Djanogly 8th Oct
Practice notes
Provisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules governing what companies can do with carried-forward...
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26th Sep
Practice notes
FORTHCOMING CHANGE: HMRC is consulting on changes to the hybrid mismatch rules to ensure that they work proportionately and as intended. Amendments...
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26th Sep
Practice notes
This Practice Note considers the steps to take in relation to SDLT once it is established there is a chargeable transaction. For details about the...
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26th Sep
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 26th Sep
Practice notes
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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26th Sep
Practice notes
This Practice Note is about the issues that arise on a transfer of a going concern involving land and buildings.A transfer of a going concern (TOGC)...
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26th Sep
Practice notes
The substantial shareholdings exemption (SSE) is an exemption from corporation tax on chargeable gains for certain share disposals by companies. The...
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26th Sep
Practice notes
BackgroundOn 6 July 2018, the government published draft legislation to be included in Finance Bill 2019 (formally the Finance (No 3) Bill 2017–19,...
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26th Sep
Practice notes
Stamp duty land tax (SDLT) is charged on chargeable land transactions. Consequently, the concept of a land transaction and what this encompasses is...
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25th Sep
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is...
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25th Sep
Practice notes
If an exemption from stamp duty applies, a document (ie an instrument of transfer) which would otherwise be subject to UK stamp duty is exempt from...
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25th Sep
Practice notes
Unless an exemption or relief applies, payments of:•yearly interest (or amounts that are treated by tax legislation as payments of yearly interest),...
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25th Sep
Practice notes
The amount of stamp duty land tax (SDLT) payable on a chargeable transaction is determined by reference to the 'chargeable consideration' for the...
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25th Sep

Most recent Basic principles content

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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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25th Sep
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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26th Sep
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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26th Sep
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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26th Sep
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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26th Sep
Practice notes
STOP PRESS relating to insolvency and tax: Finance Act 2020 introduced provisions where:•with effect for business insolvencies that commence on or...
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26th Sep
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 26th Sep
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 26th Sep
Q&As
As set out in Practice Note: Tax consequences for close companies, if a close company makes a loan to a participator, the company must pay an amount...
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28th Sep
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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28th Sep
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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28th Sep
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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29th Sep
Q&As
A director’s liability for a company’s unpaid tax debtsAs a general principle, a limited company is liable for its own debts and the company’s...
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29th Sep
Q&As
The meaning of connected persons is applied in various tax provisions. It is important to consider the detailed legislation set out in sections...
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29th Sep

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