Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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...
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:...
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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...
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...
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...
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
Capital allowances for plant and machinery are given only if specifically claimed by completing the relevant boxes on an annual tax return.Allowances...
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...
Certain items of plant and machinery (see Practice Note: Plant and machinery allowances—definition of plant and machinery) are classified as ‘integral...
Capital allowances are available for qualifying capital expenditure on know-how where the acquirer is not within the corporate intangibles tax regime...
Capital allowances are available and provide a deduction for capital expenditure on acquiring two particular types of intangible fixed asset:•patents...
Capital allowances for plant and machinery are given only if specifically claimed by completing the relevant boxes on an annual tax return.Allowances...
Research and development (R&D) capital allowances are available to all taxpayers carrying on a trade, not just companies. Therefore, an individual, or...
For both plant and machinery allowances and structures and buildings allowances (SBAs), anti-avoidance rules exist to prevent persons from obtaining a...
What is an enhanced capital allowance?An enhanced capital allowance (ECA) is a tax relief for businesses on their investments in certain categories of...
Capital allowances are the means by which a taxpayer can obtain a deduction when calculating taxable profits for some, but not all, forms of capital...
Provisions exist to ensure, generally, that assets may not be transferred between connected persons in such a way as to accelerate capital allowances...
Expenditure incurred on or after 29 October 2018 on non-residential structures and buildings which does not qualify for plant and machinery allowances...
[Date][Transferor's name and Unique Taxpayer Reference (UTR)][Transferee's name and UTR]Election to apportion the price of fixtures under section 198...
[Date][Grantor's name and Unique Taxpayer Reference (UTR)][Grantee's name and UTR]Election to apportion the price of fixtures under section 199 of the...
1Capital allowances1.1In this clause 1:CAA 2001•means Capital Allowances Act 2001Fixtures•means those items forming part of the Tenant’s Works which...
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