Capital gains

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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
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 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
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
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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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 Capital gains content

Practice notes
FORTHCOMING CHANGE relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on draft...
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20th 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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19th Jan
Practice notes
ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons...
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Produced in partnership with Alison Cartin of Bryan Cave Leighton Paisner 15th Jan
Practice notes
CORONAVIRUS (COVID-19): CIOT has asked the government to consider delaying changes to principal private residence relief (PPR) (which are due to take...
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Produced in partnership with Alison Cartin of Bryan Cave Leighton Paisner 15th Jan
Practice notes
FORTHCOMING CHANGE: On 14 July 2020, the Office of Tax Simplification (OTS) published its online survey and a call for evidence to seek views about...
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15th Jan
Practice notes
This Practice Note sets out how the capital allowances rules interact with the rules relating to:•capital gains tax, including corporation tax on...
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Produced in partnership with Martin Wilson 15th Jan
Practice notes
Companies that are members of the same capital gains group may transfer assets between themselves free of corporation tax on chargeable gains (CGT),...
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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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15th Jan
Practice notes
For a taxable capital gain to arise, there has to be a disposal, or a deemed disposal, of an asset. The taxpayer will need to establish when the...
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15th Jan
Practice notes
Tax relief for chargeable gains is available for both:•the shareholders of a company, and•the company itselfunder a scheme of reconstruction provided...
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15th 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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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The annual tax on enveloped dwellings (ATED) was introduced in Finance Act 2013...
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15th Jan
Practice notes
This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company...
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15th Jan
Practice notes
The way consideration payable for the acquisition of shares is structured is not always straightforward. In many cases payment can be delayed,...
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15th Jan
Practice notes
The capital gains legislation makes it possible for groups of companies to arrange to set allowable losses arising in one member of the group against...
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15th Jan
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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15th Jan
Practice notes
Some company acquisitions that involve a corporate buyer will be structured so that the consideration payable is the issue of new shares and/or loan...
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15th Jan
Practice notes
The capital gains legislation includes specific provisions for persons who are connected with one another. These provisions can be divided into two...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The value shifting rules are anti-avoidance provisions. They are similar to the...
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15th Jan
Practice notes
The rules dealing with depreciatory transactions and dividend stripping are anti-avoidance provisions.They target the artificial transfer of value out...
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15th Jan

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